How has the US Supreme Court interpreted its statutory presumption of intent to defraud?

Mr. Justice Roberts in Tot v. United States (1942) 319 U.S. 463, 63 S.Ct. 1241, 1243, 87 L.Ed. 1519, speaking for the majority of the court, analyzed the statutory presumption that the possession of a firearm by a person previously convicted of a crime of violence or by a fugitive from justice was prima facie evidence that he 'shipped or transported or received * * * in interstate * * * commerce'

Page 740

In the earlier case of Bailey v. Alabama (1910) 219 U.S. 219, 31 S.Ct. 145, 55 L.Ed. 191 the court invalidated a statutory presumption of an intent to defraud based upon a breach of contract of employment by an employee who had received an advance payment. Mr. Justice Hughes for the court analyzed the vice of the statutory presumption: 'Unless * * * [the defendant] were fortunate enough to be able to command evidence of circumstances affirmatively showing good faith, he was helpless. He stood, stripped by the statute of the presumption of innocence, and exposed to conviction for fraud upon evidence only of breach of contract and failure to pay.' (P. 236, 31 S.Ct. p. 149.)