burden-shifting presumption (South Carolina) · Go Syfert
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burden-shifting presumption in South Carolina

7 South Carolina opinions name it 2 courts 1984–1996 0 in the last five years

The cases below were cited by South Carolina courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (2)

CaseFollowedCited
State v. Nevagreen
sc · 1990 · cited in 1 South Carolina opinions naming this issue, 1996–1996
2 sentences

1996State v. Neva, 300 S.C. 450, 452 , 388 S.E.2d 791, 792 (1990) (emphasis added) (charge that "keeping a child out of state in violation of a custody order for a period in excess of seventytwo hours shall be prima facie evidence that the person charged intended to violate the court order" and further, that the presumption was rebuttable, was a burden-shifting instruction). *526 It is apodictic that the phrase "prima facie" [1] is anathema in a jury charge.

1996State v. Neva, 300 S.C. 450, 452 , 388 S.E.2d 791, 792 (1990) (emphasis added) (charge that "keeping a child out of state in violation of a custody order for a period in excess of seventytwo hours shall be prima facie evidence that the person charged intended to violate the court order" and further, that the presumption was rebuttable, was a burden-shifting instruction). *526 It is apodictic that the phrase "prima facie" [1] is anathema in a jury charge.

11
State v. Blassingamegreen
sc · 1978 · cited in 1 South Carolina opinions naming this issue, 1989–1989
1 sentence

1989State v. Price, 289 S. C. 32, 344 S. E. (2d) 605 (1986); see also State v. Blassingame, 271 S. C. 44, 244 S. E. (2d) 528 (1978) (intent is an element of voluntary manslaughter).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in South Carolina. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Francis v. Franklin green
scotus · 1985
2 sentences

1986Francis v. Franklin , 471 U.S. ___ , 105 S. Ct. 1965 , 85 L.Ed. (2d) 344 (1985); Sandstrom v. Montana , 442 U.S. 510 , 99 S.Ct. 2450 , 61 L.Ed. (2d) 39 (1979).

1986Francis v. Franklin, 471 U. S. _ , 105 S. Ct. 1965 , 85 L.

31985–1986
Sandstrom v. Montana green
scotus · 1979
2 sentences

1996In Sandstrom v. Montana, 442 U.S. 510 , 99 S.Ct. 2450 , 61 L.Ed.2d 39 (1979), the United States Supreme Court held that an instruction that the law presumes a person intends the ordinary consequences of his acts could be interpreted by a jury as either a burden-shifting presumption or a conclusive presumption.

1996In Sandstrom v. Montana, 442 U.S. 510 , 99 S.Ct. 2450 , 61 L.Ed.2d 39 (1979), the United States Supreme Court held that an instruction that the law presumes a person intends the ordinary consequences of his acts could be interpreted by a jury as either a burden-shifting presumption or a conclusive presumption.

21986–1996
State v. Adams green
sc · 1987
2 sentences

1996State v. Adams, 291 S.C. 132 , 352 S.E.2d 483 (1987); State v. Peterson, supra. State v. Neva, 300 S.C. 450, 452 , 388 S.E.2d 791, 792 (1990) (emphasis added) (charge that “keeping a child out of state in violation of a custody order for a period in excess of seventy-two hours shall be prima facie evidence that the person charged intended to violate the court order” and further, that the presumption was rebuttable, was a burden-shifting instruction).

1996State v. Adams, 291 S.C. 132 , 352 S.E.2d 483 (1987); State v. Peterson, supra. State v. Neva, 300 S.C. 450, 452 , 388 S.E.2d 791, 792 (1990) (emphasis added) (charge that “keeping a child out of state in violation of a custody order for a period in excess of seventy-two hours shall be prima facie evidence that the person charged intended to violate the court order” and further, that the presumption was rebuttable, was a burden-shifting instruction).

11996–1996
State v. Key green
sc · 1984
2 sentences

1992Cf. State v. Patrick, 289 S.C. 301 , 345 S.E. (2d) 481 (1986) (wherein our Supreme Court noted that jury instructions creating a burden-shifting presumption are unconstitutional and admonished trial judges that it is best to never use words such as “rebuttable” in any jury charge), overruled in part on other grounds, Casey v. State, — S.C. —, 409 S.E. (2d) 391 (1991); State v. Key, 282 S.C. 413 , 319 S.E. (2d) 338 (1984) (wherein our Supreme Court reversed a conviction for possession of marijuana with intent to distribute because of a burden-shifting jury charge).

1992Cf. State v. Patrick, 289 S.C. 301 , 345 S.E. (2d) 481 (1986) (wherein our Supreme Court noted that jury instructions creating a burden-shifting presumption are unconstitutional and admonished trial judges that it is best to never use words such as “rebuttable” in any jury charge), overruled in part on other grounds, Casey v. State, — S.C. —, 409 S.E. (2d) 391 (1991); State v. Key, 282 S.C. 413 , 319 S.E. (2d) 338 (1984) (wherein our Supreme Court reversed a conviction for possession of marijuana with intent to distribute because of a burden-shifting jury charge).

11992–1992
Casey v. State green
sc · 1991
1 sentence

1992Cf. State v. Patrick, 289 S.C. 301 , 345 S.E. (2d) 481 (1986) (wherein our Supreme Court noted that jury instructions creating a burden-shifting presumption are unconstitutional and admonished trial judges that it is best to never use words such as “rebuttable” in any jury charge), overruled in part on other grounds, Casey v. State, — S.C. —, 409 S.E. (2d) 391 (1991); State v. Key, 282 S.C. 413 , 319 S.E. (2d) 338 (1984) (wherein our Supreme Court reversed a conviction for possession of marijuana with intent to distribute because of a burden-shifting jury charge).

11992–1992
State v. Patrick green
sc · 1986
2 sentences

1992Cf. State v. Patrick, 289 S.C. 301 , 345 S.E. (2d) 481 (1986) (wherein our Supreme Court noted that jury instructions creating a burden-shifting presumption are unconstitutional and admonished trial judges that it is best to never use words such as “rebuttable” in any jury charge), overruled in part on other grounds, Casey v. State, — S.C. —, 409 S.E. (2d) 391 (1991); State v. Key, 282 S.C. 413 , 319 S.E. (2d) 338 (1984) (wherein our Supreme Court reversed a conviction for possession of marijuana with intent to distribute because of a burden-shifting jury charge).

1992Cf. State v. Patrick, 289 S.C. 301 , 345 S.E. (2d) 481 (1986) (wherein our Supreme Court noted that jury instructions creating a burden-shifting presumption are unconstitutional and admonished trial judges that it is best to never use words such as “rebuttable” in any jury charge), overruled in part on other grounds, Casey v. State, — S.C. —, 409 S.E. (2d) 391 (1991); State v. Key, 282 S.C. 413 , 319 S.E. (2d) 338 (1984) (wherein our Supreme Court reversed a conviction for possession of marijuana with intent to distribute because of a burden-shifting jury charge).

11992–1992
State v. Price neutral
sc · 1986
1 sentence

1989State v. Price, 289 S. C. 32, 344 S. E. (2d) 605 (1986); see also State v. Blassingame, 271 S. C. 44, 244 S. E. (2d) 528 (1978) (intent is an element of voluntary manslaughter).

11989–1989
Cupp v. Naughten green
scotus · 1973
2 sentences

1984Cupp v. Naughten, 414 U. S. 141 , 94 S. Ct. 396 , 38 L.

1984Cupp v. Naughten, 414 U. S. 141 , 94 S. Ct. 396 , 38 L.

11984–1984

Statutes the citing opinions construe

SC § S.C. Code Ann. § 16-3-25 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 256 (1985–2026) OH 203 (1990–2026) CA 190 (1985–2026) MI 113 (1980–2026) NJ 79 (1991–2026) CT 65 (1988–2026) TN 52 (1999–2026) NY 48 (1980–2026) WA 41 (1981–2025) MA 38 (1980–2026) PA 35 (1976–2026) KY 32 (2005–2026) FL 32 (1988–2026) GA 30 (1981–2025) ME 29 (2003–2025) LA 28 (1992–2023) IN 27 (1991–2026) MN 26 (1997–2025) MO 25 (1998–2025) NC 24 (2005–2025) IL 24 (1998–2026) OR 23 (1994–2026) IA 23 (1985–2026) KS 22 (1979–2024) VT 21 (1982–2025) RI 20 (2001–2019) HI 18 (1996–2025) DC 17 (1995–2026) WV 14 (1982–2025) MD 14 (1976–2026) UT 12 (1999–2025) ID 11 (1980–2023) VA 11 (1990–2026) AZ 10 (1982–2026) WI 10 (1979–2025) AL 10 (1991–2023) CO 10 (1990–2025) NV 10 (2020–2025) NE 10 (2006–2024) DE 8 (2011–2025) SC 7 (1984–1996) NM 7 (1991–2025) AK 7 (1982–2022) SD 6 (2003–2019) MT 6 (1979–2007) MS 4 (2000–2020) NH 4 (2016–2025) WY 4 (2007–2018) OK 2 (2012–2020) ND 2 (2001–2004) AR 2 (1951–2011) PR 2 (2011–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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