Martin v. Ohio, 480 U.S. 228 (1987), is a criminal case in which the United States Supreme Court held that the presumption of innocence requiring prosecution to prove each element of a crime beyond a reasonable doubt only applies to elements of the offense, and does not extend to the defense of justification, whereby states could legislate a burden on the defense to prove justification.[1]: 18 The decision was split 5–4.[1]: 18 The decision does not preclude states from requiring such a burden on the prosecution in their laws.[1]: 18