In the Virginia Case, Lindsey V

In the Virginia case, Lindsey v. Commonwealth, store employees observed that the defendant concealed two items of merchandise under his clothing. The defendant was brought to trial for petty larceny and was convicted. While the prosecution has the burden of proof in a criminal case, the trial judge indicated that the jury could infer that willful concealment of goods or merchandise while still on the premises of a store was evidence of an intent to convert and defraud the owner of the value of the goods or merchandise. Defendant Lindsey contended that the jury instruction amounted to a mandatory but rebuttable presumption that the defendant intended to defraud the owner of the property unless the defendant were able to convince him otherwise. The prosecution contended that the jury instruction was merely the use of an inference that the jury could adopt or refuse to adopt and therefore the jury instruction did not reverse the burden of proof and place it on the defendant. How did the reviewing court rule? What was the reviewing court's essential rationale?