SANDSTROM V. MONTANA
442 U.S. 510 (1979)
NATURE OF THE CASE: This was an appeal from a conviction of deliberate murder and a
dispute over the constitutionality of a jury instruction such that the law presumes that a
person intends the ordinary consequences of his voluntary acts.
FACTS: Sandstrom (D) confessed to the slaying of Annie Jessen. Based on that confession
and corroborating evidence, D was tried for deliberate homicide. At the trial, D's attorney
informed the jury that his client admitted to killing, Annie but did not do so purposefully
or knowingly and was therefore not guilty of a deliberate homicide. Two court appointed
mental health experts described D's mental state and D's attorney argued that this testimony
demonstrated that due to a personality disorder aggravated by alcohol consumption, D 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. D objected as this instruction shifted the burden of proof on the issue of purpose or
knowledge. The objection was overruled. D was found guilty and appealed. The Supreme Court
of Montana affirmed.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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