Sandstrom v. Montana – Case Brief
Sandstrom v. Montana, 442 U.S. 510. 99 S.Ct. 2450. 61 L.Ed.2d 39 (1979).
Facts: Sandstrom was tried for the deliberate murder of Annie Jessen based on his confession and corroborating evidence. At trial, Sandstrom’s attorney told the jury that his client admitted to killing the victim, but that he had not done so purposefully or knowingly and was therefore not guilty of a deliberate homicide. Two court appointed mental health experts described Sandstrom’s mental state and Sandstrom’s attorney argued that their testimony showed that due to a personality disorder aggravated by alcohol consumption, Sandstrom did not kill Annie purposefully or knowingly.
The prosecution requested that the judge instruct the jury that the law presumes that a person intends the ordinary consequences of his voluntary acts. Sandstrom objected, arguing that this instruction shifted the burden of proof on the issue of purpose or knowledge to the defendant. The objection was overruled. Sandstrom was found guilty and appealed. The Supreme Court of Montana affirmed and the United States Supreme Court granted cert.
Issue: Is a jury instruction that the law presumes that a person intends the ordinary consequences of his voluntary acts proper in a criminal case?
Holding and Rule (Brennan): No. A jury instruction that the law presumes that a person intends the ordinary consequences of his voluntary acts is not proper in a criminal case.
Depending on different interpretations, the jury could have determined that such an instruction was conclusive or even that it shifted the burden of persuasion on the issue of intent to Sandstrom. This instruction as issued cannot be valid. This instruction was unconstitutional because the jury at Sandstrom’s trial may have interpreted the judge’ instruction as constituting either a burden shifting presumption or a conclusive presumption and either of those interpretations would have deprived Sandstrom of due process of law.
Disposition: Reversed and Remanded.