Dixon v. United States
Dixon was convicted in federal court of receiving a firearm while under indictment and making a false statement to purchase a firearm. At trial, Dixon had raised a defense of duress, arguing that she suffered from battered woman's syndrome. The district court judge instructed the jury that Dixon had the burden of proving her duress defense by a preponderance of the evidence. The jury found against her, and she appealed. The Court of Appeals for the Fifth Circuit rejected her argument that the United States should be required to prove the absence of duress beyond a reasonable doubt, ruling that a duress defense is an affirmative defense, which means that the burden of proof is on the defendant. Thus, the Fifth Circuit affirmed her conviction.
Question Presented:
Where a criminal defendant raises a duress defense, whether the burden of persuasion should be on the government to prove beyond a reasonable doubt the defendant was not under duress, or upon the
defendant to prove duress by a preponderance of the evidence.
