The following excerpt is from Martinez v. Garcia, 371 F.3d 600 (9th Cir. 2004):
"The Due Process Clause of the Fourteenth Amendment denies States the power to deprive the accused of liberty unless the prosecution proves beyond a reasonable doubt every element of the charged offense." Carella v. California, 491 U.S. 263, 265, 109 S.Ct. 2419, 105 L.Ed.2d 218 (1989) (citation omitted). "Jury instructions relieving States of this burden violate a defendant's due process rights." Id. (citations omitted).
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