Brief Fact Summary. Defendant was convicted of “deliberate homicide” for killing Annie Jensen. He admitted to the killing but argued that he lacked the intentional element of the crime because of a personality disorder made worse by alcohol use.
Synopsis of Rule of Law. The Fourteen Amendment requires every element of a crime to be proved by the State beyond a reasonable doubt.
Issue. Does the jury instruction “the law presumes that a person intends the ordinary consequences of his voluntary acts” violate the Fourteenth Amendment?
Held. Justice Brennan issued the opinion of the United States Supreme Court in reversing the conviction and holding that the instruction could have been interpreted by the jury as a presumption that shifted the burden of the criminal offense to the Defendant.
Rather, we hold that a defendant's state of mind or intent is an element of a criminal antitrust offense which must be established by evidence and inferences drawn therefrom and cannot be taken from the trier of fact through reliance on a legal presumption of wrongful intent from proof of an effect on prices.View Full Point of Law