In the case of Francis, Warden v. Franklin in 1984, the U.S. Supreme Court ruled on a matter concerning jury instructions and burden of proof in criminal cases. The respondent, Alvin Bernard Franklin was convicted for murder and armed robbery in Georgia state court. During his trial, the judge instructed jurors that they could presume malice from evidence of an intentional killing without justification or mitigation - this is known as a "mandatory presumption." On appeal to federal courts after exhausting state remedies, Franklin argued that these instructions violated his Fourteenth Amendment due process rights by shifting the burden of proof onto him to disprove malice once intent had been established. The Supreme Court agreed with Franklin's argument by a vote of 7-2. It held that while permissive presumptions (which allow but do not require jurors to infer one fact from another) are constitutional if supported by rational connection between facts proved and presumed; mandatory presumptions violate due process because they may lead juries to ignore absence of sufficient prosecution evidence on elements like mens rea (criminal intent). This decision reaffirmed importance placed upon government's obligation under Constitution to prove every element beyond reasonable doubt.

In the dissenting opinion for Francis, Warden v. Franklin, Justice Rehnquist disagreed with the majority's interpretation of Sandstrom v. Montana and its application to this case. He argued that in Sandstrom, the jury was not given any instruction on how to interpret "presumption," leading them to possibly view it as conclusive or burden-shifting; whereas in this case, jurors were clearly instructed that they could disregard such presumptions if they found evidence contradicting them. Thus, he believed there was no constitutional violation here as jurors had been properly guided by instructions unlike in Sandstrom. Furthermore, he criticized the majority's decision for potentially causing confusion among lower courts about what constitutes a permissible presumption under due process clause of Fourteenth Amendment.