Yates v. Aiken

Background

A man convicted of murder and armed robbery after a 1981 country-store robbery was sentenced to death. At his trial the jury was told that malice could be presumed from use of a deadly weapon. Years later the South Carolina Supreme Court said that instruction was wrong but refused to give him relief, saying its state decision should not apply retroactively. The man asked the U.S. Supreme Court to decide whether federal law required relief.

Reasoning

The Court considered whether the later case, Francis v. Franklin, announced a new rule or merely applied an existing rule from Sandstrom v. Montana. The Court found Francis was not a new rule but an application of the earlier principle that the Constitution requires the State to prove every element of a crime beyond a reasonable doubt. Jury instructions that create mandatory presumptions and shift the burden of proof therefore violate that constitutional protection. Because the federal rule already existed, the state court could not refuse relief on retroactivity grounds.

Real world impact

People convicted under similar burden-shifting instructions can seek federal relief because the rule predates their trials. State courts cannot avoid established federal constitutional obligations simply by calling a ruling “new.” The Supreme Court reversed the state decision and sent the case back for further proceedings consistent with federal law; further state proceedings will determine the defendant’s ultimate fate.

Dissents or concurrances

The South Carolina court’s dissent argued that the state and federal decisions should be applied retroactively in capital cases because burden-shifting instructions undermine the jury’s truth-finding role.