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Name: Stark v. Hickman
Case #: 03-17241
Court: US Court of Appeals
District 9 Cir
Opinion Date: 08/01/2006

A habeas petitioner’s due process rights were violated when the trial court charged the jury that the petitioner was presumed to be “conclusively sane.” At his murder trial, the defendant had pleaded not guilty and not guilty by reason of insanity. At the conclusion of the guilty phase, the court told the jury that it should presume that the defendant was “conclusively sane.” The jury found the defendant guilty, and subsequently found him to have been legally sane at the time of the offense. The Ninth Circuit found that the defendant was entitled to habeas relief, because the sole issue at the guilt phase was that the defendant had a mental disease or defect that precluded him from forming a specific intent. The jury was not given a definition of “sanity,” and so the judge’s instruction would have led a reasonable juror to conclude that the defendant should be presumed to not have a mental disease. This improperly relieved the state of the burden to prove a guilty mental state, and the defendant was entitled to habeas relief.