Francis v. Franklin

471 U.S. 307, 105 S. Ct. 1965 (1985)



Courts presume that jurors, conscious of the gravity of their task, attend closely the particular language of the trial court's instructions in a criminal case and strive to understand, make sense of, and follow the instructions given them. Absent an extraordinary situation in which the risk of prejudice inhering in material put before the jury may be so great that even a limiting instruction will not adequately protect a criminal defendant's constitutional rights, courts adhere to the crucial assumption underlying the constitutional system of trial by jury that jurors carefully follow instructions. Courts must assume that juries for the most part understand and faithfully follow instructions. The concept of a fair trial encompasses a decision by a tribunal that has understood and applied the law to all material issues in the case. 


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. Defendant sought habeas relief from his state court malice murder conviction on grounds that he lacked the requisite intent to kill. At trial, 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 trial court denied the habeas petition. On appeal, however, the decision was reversed on the ground that the jury instruction on intent impermissibly shifted to the defendant the burden of disproving intent. 


Was the court's instruction on intent detrimental to the case, denying the defendant of his right to due process?




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.

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