State v. A. Sanchez Jr., 399 P.3d 886

August 2014: Sanchez led police on a high-speed pursuit in Cascade County, MT; he swerved and struck Deputy Joe Dunn (who died) while other eyewitnesses and patrol video recorded the events.
After hitting Dunn, Sanchez continued to flee, later swerved toward another officer setting spikes, and was ultimately stopped, resisted arrest, and was subdued.
Sanchez was charged with deliberate homicide (felony murder), assault with a weapon, assault on a police officer, and criminal endangerment; convicted on all but one count (lesser included negligent endangerment on that count).
The District Court instructed the jury, inter alia, on presumption of innocence, proof beyond a reasonable doubt, use of circumstantial evidence to infer mental state, and gave Instruction No. 12: “When circumstantial evidence is susceptible to two interpretations, one that supports guilt and one that supports innocence, the jury determines which is most reasonable.”
Sanchez objected, arguing Instruction No. 12 undermined the reasonable-doubt standard and the presumption of innocence; the State argued instructions taken as a whole were correct and the case relied largely on direct evidence.
Supreme Court of Montana affirmed Sanchez’s convictions, holding the instructions as a whole properly preserved the State’s burden of proof and did not prejudice Sanchez’s substantial rights.

Issue	Plaintiff's Argument (Sanchez)	Defendant's Argument (State)	Held
Whether Instruction No. 12 ("most reasonable" circumstantial-evidence rule) relieved the State of proving guilt beyond a reasonable doubt	The instruction lets jury convict on a "reasonable" interpretation of circumstantial evidence, conflicting with the presumption of innocence and the beyond-a-reasonable-doubt standard	Instructions read as a whole required proof beyond a reasonable doubt; the disputed instruction merely helps resolve competing interpretations of circumstantial evidence and did not shift the burden	Court affirmed: as part of the full set of instructions the "most reasonable" instruction did not relieve the State of its burden or affect Sanchez's substantial rights

State v. Misner, 168 P.3d 679 (Mont. 2007) (rejects rule that jury must adopt innocence-favoring interpretation when two interpretations are equally persuasive)
State v. Bullman, 203 P.3d 768 (Mont. 2009) (approves instruction directing factfinder to choose the most reasonable interpretation of circumstantial evidence)
State v. Rosling, 180 P.3d 1102 (Mont. 2008) (supports most-reasonable circumstantial-evidence instruction)
State v. Lucero, 693 P.2d 511 (Mont. 1984) (pre-Bowman instruction directing jury to adopt innocence-favoring interpretation when two reasonable interpretations exist)
State v. Atlas, 728 P.2d 421 (Mont. 1986) (origin of language distinguishing reasonable interpretations)
State v. Bowman, 89 P.3d 986 (Mont. 2004) (replaced prior circumstantial-evidence instruction with the most-reasonable formulation)
State v. Kaarma, 390 P.3d 609 (Mont. 2017) (instructing that jury instructions are reviewed as a whole for fairness)
State v. Zlahn, 332 P.3d 247 (Mont. 2014) (standard: district court has broad discretion in jury instructions; reversible error only if substantial rights prejudiced)