Dixon v. United States

548 U.S. 1 (2006)

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Nature of the Case

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Facts

D purchased multiple firearms at two gun shows, during the course of which she provided an incorrect address and falsely stated that she was not under indictment for a felony. D was indicted and convicted on one count of receiving a firearm while under indictment and eight counts of making false statements in connection with the acquisition of a firearm. D admitted that she knew she was under indictment when she made the purchases and that she knew doing so was a crime. D claimed that she acted under duress because her boyfriend threatened to kill her or hurt her daughters if she did not buy the guns for him. D contends that the instructions to the jury erroneously required her to prove duress by a preponderance of the evidence instead of requiring P to prove beyond a reasonable doubt that she did not act under duress. D contends that her defense 'controverted the mens rea required for conviction' and therefore the Due Process Clause requires P to retain the burden of persuasion on that element. The court of appeals affirmed and the Supreme Court granted certiorari.