In Francis v. Franklin, 471 U.S. 307 (1985), the defendant, who was an inmate, shot an individual while attempting to escape. (Id. at pp. 309-310.) The defense theory was that he fired the gun inadvertently, and thus did not intend to shoot the victim. (Id. at p. 311.) On appeal, the defendant argued that the instructions regarding intent to kill lessened the prosecution's burden of proof. (Id. at p. 313.) The challenged instructions were: "(1) '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' and (2) '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.'" (Id. at p. 309.) The United States Supreme Court held that the instructions impermissibly shifted the burden of proof by directing "the jury to presume an essential element of the offense--intent to kill--upon proof of other elements of the offense--the act of slaying another." (Id. at p. 316.) Francis v. Franklin, involved the pernicious danger of mandatory presumptions. The defendant challenged the constitutionality of two sentences contained in the jury charge: "'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.'" (Francis, 471 U.S. at p. 311.) The Supreme Court held that a reasonable juror could have understood the two sentences, even in the context of the entire charge, as a mandatory presumption that shifted to the defendant the burden of persuasion on the element of intent once the state had proved the predicate acts. (Id. at p. 325.)