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Within the past fifteen years several broadly-focused articles have identified general constitutional limits, under the due process clause, on presumptions and inferences created by statute or applied by courts in trying criminal cases.' Recently, in County Court of Ulster County, New York v. Allen,2 the Supreme Court affirmed the validity of the evidentiary devices of inferences and presumptions and labeled them "a staple of our adversary system of factfinding."3 This suggests that to unreasonably curtail the use of circumstantial evidence in the factfinding process would place an intolerable burden on prosecutors in their efforts to prove guilt beyond a reasonable doubt. Yet, notwithstanding the necessary evidentiary role for presumptions and inferences in the criminal justice process, the Court has acknowledged often-stated requirements of

A Due Process Analysis of Judicially-Authorized Presumptions in Federal Aggravated Bank Robbery Cases