Francis v. Franklin

Franklin (defendant), fleeing custody with a hostage, shot and killed a homeowner, Collie, after Collie slammed the door on his demand for car keys; Franklin claimed the shooting was accidental and offered circumstantial evidence — including his lack of force against others during the flight and his post-arrest statement — to argue he lacked the intent required for malice murder. The trial judge instructed the jury that a person of sound mind is presumed to intend the natural and probable consequences of his acts, that these presumptions were rebuttable, and separately that intent could not be presumed and the state bore the burden of proof on every element. Franklin was convicted, and Georgia's courts denied relief.