The U.S. Supreme Court case County Court of Ulster County, New York v. Allen (1978) revolved around the constitutionality of a New York law that presumed possession of firearms found in an automobile to be possessed by all occupants unless one occupant claimed ownership. The respondents, three siblings and their cousin, were charged with criminal possession after police discovered two loaded handguns in their car during a traffic stop for speeding. They argued that the presumption violated due process as it shifted the burden of proof from prosecution to defense. In its decision, the Supreme Court upheld the statute's constitutionality on grounds that it did not violate due process rights under Fourteenth Amendment because it was not unreasonable or arbitrary; rather than shifting burden entirely onto defendants, it merely allowed jurors to infer guilt based on established facts about firearm presence and control within vehicle. However, they also noted this inference could be rebutted if credible evidence suggested otherwise.

In the dissenting opinion for County Court of Ulster County, New York v. Allen, Justice William H. Rehnquist argued that the majority's decision to uphold a presumption of guilt in cases involving firearm possession was inconsistent with previous Supreme Court rulings on due process rights and burden of proof standards. He contended that this ruling violated defendants' constitutional right to be presumed innocent until proven guilty beyond reasonable doubt by shifting the burden onto them to prove their innocence once they were found in possession of firearms used in criminal activity. Furthermore, he criticized the majority's reliance on legislative intent as justification for upholding such presumptions, arguing it was not within judicial purview to speculate about lawmakers' intentions when interpreting statutes.