Jackson v. Virginia

In Jackson v. Virginia (1979) 443 U.S. 307, the United States Supreme Court held that "an essential of the due process guaranteed by the Fourteenth Amendment is that no person shall be made to suffer the onus of a criminal conviction except upon sufficient proof -- defined as evidence necessary to convince a trier or fact beyond a reasonable doubt of the existence of every element of the offense." The Jackson court hypothesized that if a jury were instructed that proof by a preponderance of the evidence was sufficient to convict, even though proof of guilt had been overwhelming, such a conviction would be a denial of due process. ( Id., at p. 320, fn. 14.) In other words, such error would be reversible per se.