Francis v. Franklin

471 U.S. 307 (1985)

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Nature of the Case

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Facts

Franklin, (D), a prisoner sought to escape custody while he and three other prisoners were receiving dental care at a local dentist's office. The four prisoners were secured by handcuffs to the same 8-foot length of chain as they sat in the dentist's waiting room. D was released from the chain, taken into the dentist's office and given preliminary treatment, and then escorted back to the waiting room. As another prisoner was being released, D, who had not been reshackled, seized a pistol from one of the two officers and managed to escape. He forced the dentist's assistant to accompany him as a hostage. D fled on foot with the dental assistant after refusing her request to be set free. D made two attempts to acquire a car. They were unsuccessful. D and his hostage came to the home Collie. Collie, a retired 72-year-old carpenter, answered. D was pointing the stolen pistol at the door when Collie arrived. D demanded his car keys, and Collie slammed the door. At this moment, D's gun went off. The bullet traveled through the wooden door and into Collie's chest killing him. Seconds later the gun fired again. The second bullet traveled upward through the door and into the ceiling of the residence. The dental assistant fled, and D entered the house, demanded the car keys from the victim's wife, and added the threat 'I might as well kill you.' D then stepped outside and encountered the victim's adult daughter. He repeated his demand for car keys but made no effort to stop the daughter when she refused the demand and fled. Failing to obtain a car, D left and remained at large until nightfall. D made a formal statement to the authorities in which he admitted that he had shot the victim but emphatically denied that he did so voluntarily or intentionally. He claimed that the shots were fired in accidental response to the slamming of the door. D was charged with a capital offense. D claimed that the circumstances surrounding the firing of the gun, particularly the slamming of the door and the trajectory of the second bullet, supported the hypothesis of accident, and that his immediate confession to that effect buttressed the assertion. He also argued that his treatment of every other person encountered during the escape indicated a lack of disposition to use force. The judge instructed the jury in part that: The acts of a person of sound mind and discretion are presumed to be the product of the person's will, but the presumption may be rebutted. A person of sound mind and discretion is presumed to intend the natural and probable consequences of his acts, but the presumption may be rebutted. The jury deliberated and then requested reinstruction on the element of intent and the definition of accident. The jury deliberated 10 more minutes and returned a verdict of guilty. D was sentenced to death for the murder conviction. Eventually, D sought federal habeas corpus relief, pursuant to 28 U.S.C. § 2254. The district court denied the application without an evidentiary hearing. D appealed to the Eleventh Circuit. The Court of Appeals reversed the District Court and ordered that the writ issue. The court held that the jury charge on the dispositive issue of intent could have been interpreted by a reasonable juror as a mandatory presumption that shifted to the defendant a burden of persuasion on the intent element of the offense. The Supreme Court granted certiorari.