Dixon v. United States

In Dixon v. United States (2006) U.S. 126 S. Ct. 2437, the petitioner was indicted and convicted on one count of receiving a firearm while under indictment in violation of title 18 United States Code section 922(n), and eight counts of making false statements in connection with the acquisition of a firearm in violation of title 18 United States Code section 922(a)(6). The petitioner contended she acted under duress because her boyfriend threatened to kill her or harm her children if she did not buy the guns for him. (Dixon v. United States, supra, U.S. at p. 126.) The petitioner argued the trial court erred by instructing the jury that she had the burden to prove the duress defense, and by rejecting her contention that the government was required to disprove the defense beyond a reasonable doubt. (Id. at p. 126 S. Ct. at p. 2440.) The Supreme Court held the government bore the burden of proving beyond a reasonable doubt that the petitioner acted with knowledge her acts were unlawful, which it did. (Dixon v. United States, supra, U.S. at p. 126 S. Ct. at p. 2441.) The high court further held that the petitioner bore the burden of proving the defense of duress: "The duress defense . . . may excuse conduct that would otherwise be punishable, but the existence of duress normally does not controvert any of the elements of the offense itself." (Id. at p. 126 S. Ct. at p. 2441.) Therefore, the high court concluded the jury instructions were proper and did not violate the petitioner's due process rights. (Id. at p. 126 S. Ct. at p. 2442.)