In Ulster County Court v. Allen, 442 U.S. 140, 99 S.Ct. 2213, 60 L.Ed.2d 777 (1979), defendants had been convicted of illegal possession of handguns under a New York statute, which stated that the presence of a firearm in an automobile was presumptive evidence of its possession by all persons in that vehicle. Allen, 99 S.Ct. at 2217. Defendants claimed this presumption violated due process, but the Court disagreed and denied their habeas corpus petition. The Court pointed out that the trial judge instructed the jury not only on the statutory presumption, but also on the customary burden that the government prove its case beyond a reasonable doubt. Id. at 2227. It concluded that use of the presumption was constitutional. Id. at 2229-30.