Sandstrom v. Montana
United States Supreme Court
442 U.S. 510 (1979)
David Sandstrom (defendant) confessed to killing Annie Jessen but argued he was guilty only of a lesser offense than deliberate homicide because a personality disorder, aggravated by alcohol, kept him from acting "purposely or knowingly." Over defense objection, the trial court instructed the jury that "the law presumes that a person intends the ordinary consequences of his voluntary acts," and Sandstrom was convicted of deliberate homicide. The Montana Supreme Court found the instruction shifted some burden to Sandstrom but affirmed anyway, reasoning some burden-shifting was permissible.
Whether instructing a jury to make a presumption that eliminates the government's burden to prove intent, or shifts that burden to the defendant, violates due process.