Casey v. United States

Background

A Seattle lawyer was tried after jail inmates and federal agents said he agreed to obtain morphine and delivered it concealed in laundry. He was indicted on two counts (purchase and sale); the Government admitted the sale count was bad, so the Court reviewed only the purchase charge and the supporting evidence about his visits, payments, and the soaked towels that tested positive for morphine.

Reasoning

The central question was whether merely possessing morphine without the required tax stamps could let jurors infer an unlawful purchase in the district. The majority held that the statute creates a prima facie presumption from possession that shifts the burden to the person found with the drug to explain how they got it. The Court found testimony about the lawyer’s habits, payments, and the circumstances sufficient to support the jury’s inference and rejected the idea that the record showed the Government induced the crime.

Real world impact

The decision means people found with unstamped narcotics can face convictions even without direct proof of where they bought the drug, unless they can offer a satisfactory explanation. It endorses the use of statutory presumptions in narcotics cases and narrows the relief available for entrapment-type arguments when the record does not clearly show government provocation.

Dissents or concurrances

Several Justices dissented, arguing the presumption unreasonably shifts the burden of proof and that government agents effectively provoked the offense here, so the prosecution should have been barred to protect the courts’ integrity.