Sunday, November 17, 2013

Francis v. Franklin case brief

Francis v. Franklin case brief summary
471 U.S. 307 (1985)

Defendant sought habeas relief from his state court malice murder conviction on grounds that he lacked the requisite intent to kill. The United States Court of Appeals for the Eleventh Circuit reversed the decision denying defendant's habeas petition because the jury instruction on intent impermissibly shifted to the defendant the burden of proving intent. The government petitioned for certiorari.

During events following defendant's taking of a hostage and escape from custody, a shot he fired killed an individual on the other side of a closed door. Defendant denied firing the shot voluntarily or intentionally and claimed that shots were fired in accidental response to the slamming of the door. The jury was instructed that a person's acts were presumed to be the product of his will and that a person was presumed to intend the consequences of his acts, but that such presumptions could be rebutted.


  • The Court held that the jury charge on the dispositive issue of intent did not comport with the requirements of the Due Process Clause. 
  • The Court noted that the challenged sentences were cast in the language of command. 
  • The jurors were not told that they had a choice, or that they might infer the stated conclusions, but only that the law so presumed. 
  • The Court reasoned that a rational juror could have understood the challenged portions of the jury instructions as creating a mandatory presumption that shifted to defendant the government's burden of persuasion on the crucial element of intent. 
  • The Court also concluded that the charge read as a whole did not explain or cure the error.

The decision that reversed the denial of federal habeas corpus relief to defendant was affirmed. The Due Process Clause of the Fourteenth Amendment prohibited the state from using the jury instructions given at defendant's murder trial because they relieved the state of its burden of proving the element of intent.

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