## Facts

- Raymond Lee Franklin, a Georgia prisoner, was taken from prison to a dentist under guard.
- Franklin stole a guard’s gun and escaped.
- While fleeing, he confronted a nearby homeowner seeking car keys; as the homeowner slammed the front door, Franklin’s pistol fired through the door, killing the homeowner.
- Franklin’s only defense at trial was lack of intent to kill; he argued the shooting was accidental.
- The trial court instructed the jury that a person of sound mind is “presumed to intend the natural and probable consequences of his acts,” adding that the presumption “may be rebutted,” and also gave general instructions on the presumption of innocence and the State’s burden to prove each element beyond a reasonable doubt.
- The jury convicted Franklin of malice murder and he was sentenced to death.

## Issues

1. Whether an instruction stating that a person of sound mind is “presumed to intend the natural and probable consequences of his acts,” even if described as rebuttable and accompanied by general reasonable-doubt instructions, violates due process by creating a mandatory or burden-shifting presumption on intent.

## Decision

- The Supreme Court affirmed the grant of federal habeas relief.
- The Court held that the intent instruction violated the Fourteenth Amendment because a reasonable juror could understand it as requiring an inference of intent unless the defendant rebutted it.
- The Court concluded the surrounding instructions on reasonable doubt and the State’s burden did not cure the defect where the specific intent language could be read as conclusive or as shifting the burden of persuasion to the defendant.
- Dissents argued the charge should be read as a whole and that the repeated burden-of-proof instructions sufficiently prevented any burden shift.

## Legal Principles

- Due process requires conviction only upon proof beyond a reasonable doubt of every fact necessary to constitute the charged crime, including mens rea.
- A jury instruction is unconstitutional if a reasonable juror could interpret it as creating a mandatory presumption that relieves the State of the burden of persuasion on an element.
- Labeling a presumption as “rebuttable” may still be unconstitutional if it suggests the defendant must disprove the element or persuade the jury to reject the presumption.
- Correct general instructions on reasonable doubt do not necessarily neutralize a specific instruction that can reasonably be understood to shift the burden on intent.
- Permissive inferences are permitted only when the jury remains free to accept or reject the inference and the burden of proof remains on the prosecution.

## Conclusion

The Court held that an intent instruction stating a defendant is “presumed to intend the natural and probable consequences of his acts,” even with “may be rebutted” language and general reasonable-doubt instructions, violates due process when it can reasonably be read as mandatory or burden-shifting on intent.


Francis v. Franklin, 471 U.S. 307 (1985)