Does a criminal presumption under Section 1201(b) of the Criminal Code need to satisfy a "reasonable doubt" standard?

8 Since we find the 1201(b) presumption is unconstitutional under this standard, we do not reach the question of whether a criminal presumption must satisfy a "reasonable doubt" standard. See Leary v. United States, 395 U.S. 6, 36 n. 64, 89 S.Ct. 1532, 23 L.Ed.2d 57 (1969); see also Barnes v. United States, 412 U.S. 837, 842-46, 93 S.Ct. 2357, 37 L.Ed.2d 380 (1973); Turner v. United States, 396 U.S. 398, 419-24, 90 S.Ct. 642, 24 L.Ed.2d 610 (1970).

9 Both appellants are represented by counsel on appeal who did not represent them at trial.