Francis v. Franklin

Brief Fact Summary.

Franklin’s (Defendant) gun went off and killed a man during his escape from prison.

Synopsis of Rule of Law.

A jury instruction that implies that the defendant must disprove an intent to kill is unconstitutional.

Facts.

During a dental visit, Defendant, a prisoner, stole a guard’s gun and escaped. Defendant entered a house and demanded a vehicle from the occupant. The occupant said he had no vehicle and slammed the door on Defendant. The door hit Defendant’s gun, causing it to discharge. The bullet passed through the door and struck and killed the occupant. Defendant was tried for murder. The jury was instructed that the law presumes that a person intends the natural consequences of his actions. Defendant was convicted and appealed.

Issue.

Is a jury instruction that implies that a defendant must disprove an intent to kill constitutional?

Held.

:(Brennan, J.) No. A jury instruction that implies that the defendant must disprove an intent to kill is unconstitutional. The prosecution has the burden to prove each of the essential elements of the murder charge, including the intent to kill. Any jury instruction which implies otherwise is unconstitutional. The instruction given in this case could have been interpreted by the jury as saying that Defendant was presumed to have intended to kill the occupant of the house. The conviction must be reversed.

Discussion.

The difference between murder and manslaughter is that murder requires an intent to kill and manslaughter does not. Intent can be found in evidence of an actual desire to kill another or in evidence of extremely reckless behavior.