Williams v. State, 111 So. 3d 620

Williams convicted of murder in Harrison County, Mississippi, and sentenced to life in the MDOC.
She challenged jury instructions S-2A, S-4, and S-6 as error on appeal.
Williams testified the shooting was accidental; two eyewitnesses contradicted her claim.
The State offered expert testimony contradicting Williams on the intent element.
S-4 was found to create a mandatory presumption shifting the burden of proof on intent.
The court reversed and remanded for a new trial based on the error in S-4.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court erred in granting S-2A, S-4, and S-6.	Williams relied on Sandstrom/Francis to argue S-4 shifted burden.	State argued the instructions, read together, did not shift the burden.	S-4 created a mandatory presumption; error; not harmless; reversal and remand.

Sandstrom v. Montana, 442 U.S. 510 (U.S. 1979) (presumption of intent violated due process if mandatory)
Francis v. Franklin, 471 U.S. 307 (U.S. 1985) (presumptions shifting burden violate due process)
Tran v. State, 681 So.2d 514 (Miss. 1996) (presumption of deliberate design from deadly weapon improper)
Brown v. State, 965 So.2d 1023 (Miss. 2007) (deliberate design element requires proof of intent)
In re Winship, 397 U.S. 358 (U.S. 1970) (beyond a reasonable doubt required for every element)
Hodges v. State, 743 So.2d 319 (Miss. 1999) (state must prove every element beyond a reasonable doubt)
Sloan v. State, 368 So.2d 228 (Miss. 1979) (burden never shifts to defendant)
Rose v. Clark, 478 U.S. 570 (U.S. 1986) (permissible inference vs presumption)