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Sandstrom Vs. Montana

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  • US Supreme Court
  • Jun 18, 1979

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  1. Bachellar Vs. Maryland US Supreme Court · Apr 20, 1970
  2. Mullaney Vs. Wilbur US Supreme Court · Jun 09, 1975
  3. U.S. 510 (1979) U.S. Supreme Court Sandstrom v. Montana
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  4. U.S. 510 (1979) Sandstrom v. Montana
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  5. Because the jury may have interpreted the challenged presumption as conclusive, like the presumptions in Morissette v. United
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  6. States, 342 U. S. 246 , and United States v. United
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  7. States Gypsum Co., 438 U. S. 422 , or as shifting the burden of persuasion, like that in Mullaney v. Wilbur
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  8. to provide a number of federal decisions in support of the objection, including this Court's holding in Mullaney v. Wilbur
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  9. shifted to the defendant the burden of disproving an element of the crime charged, in violation of Mullaney v. Wilbur
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  10. supra, In re Winship, 397 U. S. 358 (1970), and Patterson v. New
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  11. to this kind of jury instruction is to determine the nature of the presumption it describes. See Ulster County Court v. Allen
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  12. clear that a reasonable juror could easily have viewed such an instruction as mandatory. See generally United States v. Wharton
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  13. Green v. United
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  14. warned that instructions of the type given here can be interpreted in just these ways. See generally United States v. Wharton
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  15. Berkovitz v. United
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  16. State v. Roberts
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  17. State v. Warbritton
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  18. Hall v. State
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  19. Ala.App. 381, 385, 272 So.2d 590, 593 (Crim.App. 1973). See also United States v. Chiantese
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  20. Ulster County Court v. Allen
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  21. Leary v. United
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  22. Carpenters v. United
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  23. Bollenbach v. United
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  24. Id. at 397 U. S. 364 (emphasis added). Accord, Patterson v. New
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  25. a conclusive presumption. This Court has considered such a presumption on at least two prior occasions. In Morissette v. United
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  26. footnote omitted.) Just last Term, in United States v. United
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  27. fact through reliance on a legal presumption of wrongful intent from proof of an effect on prices. Cf. Morissette v. United
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  28. Id. at 438 U. S. 435 , 438 U. S. 446 (emphasis added). See also Hickory v. United
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  29. prove that he lacked the requisite mental state. Such a presumption was found constitutionally deficient in Mullaney v. Wilbur
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  30. he acted in the heat of passion on sudden provocation. Ibid. As we recounted just two Terms ago in Patterson v. New
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  31. as bearing solely upon purpose. As we said in United States v. United
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  32. the unconstitutionality of any of the theories requires that the conviction be set aside. See, e.g., Stromberg v. California
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  33. States, 395 U.S. at 395 U. S. 31 -32. See Ulster County Court v. Allen
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  34. that, even if the jury did rely upon the unconstitutional instruction, this constituted harmless error under Chapman v. California
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  35. an element of the crime can never constitute harmless error, see generally Page 442 U. S. 527 Carpenters v. United
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  36. issues was considered by the Supreme Court of Montana, we decline to reach them as an initial matter here. See Moore v. Illinois
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  37. See Chappell v. United
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  38. Bloch v. United
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  39. Wardlaw v. United
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  40. Kan. 506, 506 P.2d 1152 (1973), Hall v. State
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  41. Ala.App. 381, 385, 272 So.2d 590, 593 (Crim.App. 1973). See also United States v. Wharton
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  42. Courts of Appeals have ordered their District Courts to delete the instruction in future cases. See United States v. Garrett
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  43. United States v. Chiantese
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  44. U.S. Supreme Court Sandstrom v. Montana
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  45. Morissette v. United
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  46. and United States v. United
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  47. of Mullaney v. Wilbur
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  48. and Patterson v. New
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  49. See Ulster County Court v. Allen
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  50. United States v. Wharton
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