Joseph Robert Reith v. State of Mississippi

Summary

The Supreme Court of Mississippi held that a jury instruction allowing deliberate design to be presumed from the unlawful and deliberate use of a deadly weapon violated the presumption of innocence and relieved the State of proving intent beyond a reasonable doubt. The court overruled conflicting prior cases, found the error was not harmless, and reversed and remanded for a new trial.

Holdings

1. A jury may never be instructed that it may presume deliberate design or intent from the unlawful and deliberate use of a deadly weapon because the instruction conflicts with the presumption of innocence and relieves the State of proving an essential element beyond a reasonable doubt.
2. The error was not harmless beyond a reasonable doubt.

Questions Presented

1. Whether the trial court erred by instructing the jury that deliberate design may be presumed from the unlawful and deliberate use of a deadly weapon.
2. Whether the instructional error was harmless beyond a reasonable doubt.

Disposition

reversed_and_remanded