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He placed himself IN that position.
So what, now if I walk in front of the firing range of criminal, I am to blame for the accident if I get shot? Just because someone walks in range doesn't give you the right to punch them.
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HE made the first move, not the heckler.
Wait, does this mean that Franklin threw the first elbow? If thats true, then he might be guilty of assualt. But, if he simply walked towards the heckler, its not enough to say that he was actively promoting the violence. If the heckler struck first, it could easily be argued that Franklin had acted in self-defense.