This section contains the nature of the case and procedural background.

Sandstrom (D) confessed to the slaying of Annie Jessen. Based on that confession and corroborating evidence, D was tried for deliberate homicide. At the trial, D's attorney informed the jury that his client admitted to killing, Annie but did not do so purposefully or knowingly and was therefore not guilty of a deliberate homicide. Two court-appointed mental health experts described D's mental state and D's attorney argued that this testimony demonstrated that due to a personality disorder aggravated by alcohol consumption, D did not kill Annie purposefully or knowingly. The prosecution requested that the judge instruct the jury that the law presumes that a person intends the ordinary consequences of his voluntary acts. D objected as this instruction shifted the burden of proof on the issue of purpose or knowledge. The objection was overruled. D was found guilty and appealed. The Supreme Court of Montana affirmed.

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