Supreme Court of the United States

Smith v. United States

January 9, 2013133 S. Ct. 714

Summary

The Supreme Court held that the Due Process Clause does not require the Government to prove beyond a reasonable doubt that a defendant did not withdraw from a conspiracy outside the statute-of-limitations period. Instead, the defendant bears the burden of proving withdrawal by a preponderance of the evidence as an affirmative defense. Justice Scalia delivered the unanimous opinion, joined by all members of the Court.