Sandstrom v. Montana

The question presented is whether, in a case in which intent is an element of the crime charged; the jury instruction, “the law presumes that a person intends the ordinary consequences of his voluntary acts,” violates the Fourteenth Amendment’s requirement that the State prove every element of a criminal offense beyond a reasonable doubt.

I

On November 22, 1976, 18-year-old David Sandstrom confessed to the slaying of Annie Jessen. Based upon the confession and corroborating evidence, petitioner was charged on December 2 with “deliberate homicide,” Mont. Code Ann. § 45-5-102 (1978), in that he…