Dixon v. United States

Brief Fact Summary.

Defendant bought multiple firearms by providing false information, including lying about her felony indictments. Defendant was charged and convicted of obtaining a firearm while having a felony indictment and for making a false statement to obtain a firearm. Defendant claims she was acting under duress and appeals her conviction to the appellate court. The appellate court affirmed the conviction. Defendant petitions for certiorari alleging the trial court improperly placed the burden on Defendant to prove her defense of duress.

Synopsis of Rule of Law.

A defendant has the burden of proving the defense of duress under federal law.

Facts.

Keshia Dixon, Defendant, went to two gun shows and bought more than one firearm. When Defendant purchased the firearms, Defendant gave an incorrect address and lied about having a felony indictment. Defendant was charged and convicted of obtaining a firearm while having a felony indictment and for making a false statement to obtain a firearm. At trial, Defendant testified that she knowingly provided false information concerning her address and indictment standing. Also, Defendant testified that she knew providing false information about her indictment was a crime. Nevertheless, Defendant asserted the defense of duress, on the grounds that her boyfriend threatened to kill her or harm her children if she did not get him the guns. Defendant appealed her conviction to the court of appeals, and the court of appeals affirmed the convictions. Thereafter, Defendant appealed the decision the United States Supreme Court alleging that the trial court improperly by placing the burden on Defendant to prove duress by a preponderance of the evidence, rather than placing the burden of proving that Defendant was not under duress on the Government. The United States Supreme Court granted certiorari.

Issue.

Whether a defendant has the burden of proving the defense of duress under federal law.

Held.

Yes, a defendant has the burden of proving the defense of duress under federal law.

Dissent.

Defendant has the burden of production, however, the Prosecution has the burden of persuasion.

Concurrence.

The majority properly ruled that Congress intended the Defendant to bare the burden of prove in this case. However, the majority incorrectly stated that the burden of proof for duress varies, depending on the charged crime.

The record does not contain evidence that Congress intended to rely on any legal principle other than common law. However, the court is not obligated to refrain from considering Model Penal Code to determine Congressional intent.

Discussion.

A defendant has the burden of proving the defense of duress, an affirmative defense, under federal law. In contrast, the Prosecution bears the burden of the charged offense beyond and to the exclusion of every reasonable doubt. Since duress is an affirmative defense, a successful showing of the defense allows a defendant to avoid liability, as it negates a finding of guilt. Notably, duress does not negate a finding of a mens rea, but solely acts as defense to liability. Further, federal crimes are created solely by statute, and each crime has a separate type of intent that results in criminal liability. Under common law, which is at issue in this case, the defendant bears the burden of proof. Further, Congress’ intent, when codifying the statute of the crimes at issue in this case, indicates that Congress wanted to apply a similar standard to duress. Furthermore, Defendant’s reliance on the Model Penal Code, which places the burden on the Prosecution to prove duress, is misplaced because Defendant has not asserted any evidence that indicates that Congress has adopted the Model Penal Code. Therefore, the lower court’s judgment is affirmed.