In Martin v. Ohio (1987) 480 U.S. 228, the United States Supreme Court held that the burden of proving self-defense could be placed on the defendant. (Id. at p. 233.) The court noted "it would be quite different if the jury had been instructed that self-defense evidence could not be considered in determining whether there was a reasonable doubt about the State's case, i.e., that self-defense evidence must be put aside for all purposes unless it satisfied the preponderance standard. Such an instruction would relieve the State of its burden . . . ." (Id. at pp. 233-234.)