Cupp v. Naughten

Background

A man named Naughten was tried in Oregon for armed robbery. The State’s case relied on the store owner’s eyewitness account, a second eyewitness, two police officers who found him near the scene and the stolen money near his car, and clothing identified as his. Naughten did not testify or call witnesses. At trial the judge told the jury that the defendant is presumed innocent and then added that “every witness is presumed to speak the truth,” while explaining how that presumption could be overcome.

Reasoning

The central question was whether that witness-truth presumption instruction violated the Constitution by shifting the burden to the defendant. The Supreme Court said the instruction must be read in context of the whole charge. Because the jury was repeatedly told about the presumption of innocence and that the State must prove guilt beyond a reasonable doubt, the Court concluded the single instruction did not rise to constitutional error. The Court also noted that the instruction came from longstanding Oregon law and that federal appellate criticism alone did not make it a Fourteenth Amendment violation.

Real world impact

The ruling means a state trial judge may give a presumption-of-truth instruction without automatically creating a constitutional defect if the overall jury instructions make the presumption of innocence and reasonable-doubt standard clear. Federal courts should not set aside state convictions solely because the instruction is widely criticized; context and the complete charge matter.

Dissents or concurrances

Three Justices dissented, arguing the instruction risked reducing the State’s burden to a mere preponderance and could not be treated as harmless, especially when the defendant did not testify.