In the case of Cupp, Penitentiary Superintendent v. Naughten in 1973, the U.S Supreme Court ruled that a jury instruction given by an Oregon state court did not violate due process rights under the Fourteenth Amendment. The defendant, Naughten, was convicted for robbery and argued that his conviction should be overturned because he believed one of the instructions given to jurors could have led them to believe they were required to accept as true any uncontradicted testimony from government witnesses. However, Justice White delivered the opinion of a unanimous court stating that while it is possible some jurors may have misunderstood this particular instruction in isolation; when viewed within context with all other instructions provided during trial proceedings - which emphasized presumption of innocence and burden on prosecution to prove guilt beyond reasonable doubt - there was no constitutional violation. Therefore, Naughten's conviction stood.

In the dissenting opinion for Cupp v. Naughten, Justice William O. Douglas argued that the jury instruction given by the trial judge was unconstitutional as it shifted the burden of proof from prosecution to defense, violating due process rights under Fourteenth Amendment. He contended that telling jurors they could presume intent from an act is akin to instructing them they must find a defendant guilty unless he proves his innocence - a clear violation of constitutional principles which state that guilt must be proven beyond reasonable doubt by prosecution. Furthermore, he criticized majority's reliance on 'totality' approach in evaluating constitutionality of instructions and emphasized each part should stand scrutiny individually because jurors might not interpret instructions as whole but rather focus on specific parts.