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Raymond Lee Franklin v. Robert Francis, Warden
Citations: 723 F.2d 770; 1984 U.S. App. LEXIS 26628Docket: 83-8022
Court: Court of Appeals for the Eleventh Circuit; January 9, 1984; Federal Appellate Court
The Eleventh Circuit Court of Appeals denied the state's petition for rehearing in the case of Raymond Lee Franklin v. Robert Francis. The court clarified its stance on jury instructions regarding intent, distinguishing between permissive and mandatory presumptions. The state referenced the case of Lamb v. Jernigan to argue that the differences between jury instructions were constitutionally significant; however, the court found that Lamb involved a permissive instruction, which did not impose a burden on the defendant. In contrast, Franklin's trial included a mandatory instruction that presumed the defendant intended the natural consequences of his acts, akin to the flawed instructions in Sandstrom v. Montana. The court emphasized that mandatory presumptions that shift the burden of proof to the defendant are unconstitutional. The state also contended that any burden-shifting was mitigated by other language in the instructions, but the court did not find that argument persuasive. The Lamb panel determined that while additional jury instructions reduced the likelihood of misinterpretation of the intent instruction, it did not address whether these instructions could rectify a defective instruction. The panel concluded that the intent instruction was not mandatory and therefore not defective. In contrast, the Corn panel found that other instructions adequately cured a defective intent instruction, noting that Corn's jury received extensive cautions against an irrebuttable presumption of intent. These included clarifications that the defendant could present evidence to negate intent without being required to do so, and that the state bore the burden of proving intent beyond a reasonable doubt. The Corn court emphasized the significance of these additional instructions in affirming the trial judge's guidance. Franklin's trial, however, lacked similar comprehensive instructions, as the only relevant instruction pertained to malice and did not mitigate the damaging presumption that individuals intend the natural consequences of their actions. The evidence presented confirmed that Franklin fired the shot resulting in Collie's death, which coincided with Collie slamming the door. The primary question for the jury was Franklin's intent, making the presumptions related to intent critical to the trial's outcome. The court expressed that it could not overlook the implications of Sandstrom, indicating that the lack of clear corrective language in the instructions precluded a reasonable juror from applying the presumption constitutionally. Thus, the Petition for Rehearing was denied.