Case Study: Jane Doe V. United States

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FACTS: Three adult men (ALLEN ET AL, respondents/defendants) and a 16-year-old girl (a Jane Doe who was not a respondent) were tried on charges that they possessed two handguns, a machine gun, and a pound of heroin found in a Chevrolet they were riding in when stopped for speeding on the New York Thruway on March 28, 1973. The handguns were seen protruding from an open handbag on the passenger side near Jane Doe, who admitted that the handbag was hers. The machine gun and the heroin were discovered in the trunk after the police forced it open. (The key to the trunk was nowhere to be found). The car belonged to, and had been borrowed from, the driver's brother. A New York statute states that the presence of a firearm in an automobile is presumptive …show more content…

Defendants filed a post-trial motion challenging the constitutionality of the New York statute as applied in this case. Motion was denied. Convictions were affirmed by the Appellate Division. The New York Court of Appeals also affirmed. Respondents/defendants filed a petition for a writ of habeas corpus in the United States District Court for the Southern District of New York, which issued the writ. The United States Court of Appeals for the Second Circuit affirmed, holding that respondents had grounds to challenge the constitutionality of the statute.

ISSUE: Was the New York statute’s possession presumption unconstitutional as applied in this case?

RULING: No. The Court reversed the judgment of the Second Circuit. See dissent below.

RATIONALE: The jury instructions stated that the presumption gave rise to a permissive inference, not a mandatory conclusion, and could be ignored even without affirmative proof from defendants. The respondents’ argument was based on the fact that the guns were in Jane Doe's handbag, however the facts indicated that Jane Doe was not the only person able to exercise control over the guns. The guns were too large to be concealed in her handbag, which was open with one of the guns in plain sight, within easy access of the driver and possibly the other men. Thus the jury could have reasonably rejected the respondents’

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