court rather than when first confronted by law enforcement in order to avoid criminal conviction based on “the minor m s direct appeal, the Supreme Court’s precedent has developed significantly in the field of state law affirmative defenses that fully satisfy the Winship baseline demand. See, e.g., Gilmore v. Taylor, 508 U.S. 333, 341, 113 S.Ct. 2112, 124 L.Ed.2d 306 (1993); Medina, 505 U.S. at 445-46, 112 S.Ct. 2572; Martin v. Ohio, 480 U.S. 228, 233-35, 107 S.Ct. 1098, 94 L.Ed.2d 267 (1987); Patterson v. New York, 432 U.S. 197, 210, 97 S.Ct. 2319, 53 L.Ed.2d 281 (1977). This precedent on affirmative defenses provides ready support for concluding that the SJC’s due process ruling in Powell’s direct appeal is not objectively unreasonable. See Patterson, 432 U.S. at 210, 97 S.Ct. 2319 (<HOLDING>); see also Martin, 480 U.S. at 238-35, 107
holding that the due process clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime charged holding state must prove every element of an offense beyond a reasonable doubt and a scheme that shifts the burden of proof to the defendant by presuming a fact upon proof of the other elements of the offense violates due process holding that due process clause of fourteenth amendment protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime for which he is charged holding that the due process clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged holding that due process does not create a constitutional imperative operative countrywide that a state must disprove beyond a reasonable doubt every fact constituting any and all affirmative defenses related to the culpability of an accused