Leroy Chasson v. Joseph Ponte
Headline: Court refuses to review jury-intent instruction cases, leaving lower courts' rulings in place and keeping convictions intact despite a dissent arguing the instructions violated due process.
Holding: The Court denied review of two cases involving jury instructions that presumed intent, leaving the lower-courts’ decisions intact and thus allowed those convictions to stand for now.
- Leaves the convictions and lower-court rulings in place for now.
- Keeps open whether presumption-of-intent jury instructions violate due process.
- Signals dissenters want Supreme Court review to protect defendants' due process rights.
Summary
Background
Leroy Chasson was convicted of first-degree murder, and Edwin Rivera was convicted of first-degree manslaughter and misdemeanor weapon possession. At both trials the judge told jurors that a person is "presumed to intend the natural consequence of his act" or gave substantially similar language. Rivera won a federal habeas writ in a District Court that the Second Circuit later reversed; Chasson’s habeas petition was denied and the First Circuit affirmed. The Supreme Court was asked to review both appeals.
Reasoning
The central question was whether a jury instruction that tells jurors to presume intent violates a defendant’s right to due process under the Court’s earlier decision in Sandstrom v. Montana (1979). Justice Marshall, joined by Justice Brennan, argued in a dissent that the challenged instructions were materially the same as the instruction condemned in Sandstrom and that later or general charge language did not remove the unconstitutional presumption. He said those defects required vacating the convictions. The Court, however, issued a one-line order denying review and did not resolve the legal issue.
Real world impact
Because the Supreme Court declined to hear the cases, the lower-court rulings and the trial convictions remain in effect for now. The denial leaves unresolved whether and when similar jury instructions must be treated as unconstitutional, and trial judges and appeals courts retain the existing disagreement about how Sandstrom should be applied.
Dissents or concurrances
Justice Marshall dissented from the denial, urging review and arguing the instructions violated due process; Justice Brennan joined that dissent.
Opinions in this case:
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