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(1895) didn’t create a new “modern common law” rule allocating the burden of proof on affirmative defenses to the government generally; rather, it “required the Government to prove the defendant's sanity beyond a reasonable doubt because the evidence that tended to prove insanity also tended to disprove an essential element of the offense charged,” citing Davis at 378. In any event, “we held in Leland [ v. Oregon, 343 U.S. 790, 797, 72 S.Ct. 1002, 96 L.Ed. 1302 (1952)] that this rule was not constitutionally mandated, and Congress overruled it by statute in 1984.” 3. Although all parties recognize the power of Congress to allocate the burden of proof differently, nothing in statute here indicates any intent to shift burden here to government. H. CLAIM OF RIGHT Stratacos v. State, 312 Ga.App. 783, 720 S.E.2d 256 (November 22, 2011). Theft by deception and related convictions affirmed; evidence didn’t support defense of claim of right. “Pursuant to OCGA § 16–8–10, ‘[i]t is an affirmative defense to a prosecution for violation of Code Sections 16–8–2 through 16–8–7 that the person ... (2) Acted under an honest claim of ... a right to acquire ... [the property] as he did....’ OCGA § 16–8–10(c). However, merely denying any intent to deprive the owner of the property does not set forth a ‘claim of right’ to the property as an affirmative defense to a theft prosecution. Mathis v. State, 147 Ga.App. 148, 149(3) (248 S.E.2d 212) (1978).” Defendant here took money for real property repairs from 10 different victims and failed to complete any of the jobs – because, he testified, of various “problems in his personal life.” Reversed on other grounds, 293 Ga. 401, 748 S.E.2d 828 (July 11, 2013). Richards v. State, 276 Ga.App. 384, 623 S.E.2d 222 (November 15, 2005). Trial court properly refused to charge jury on “claim of right” as defense to robbery by intimidation. “The ‘claim of right’ defense applies only to prosecutions for theft crimes in violation ‘of Code Sections 16-8-2 through 16-8-7’ when a defendant ‘[a]cted under an honest claim of right to the property or service involved or under a right to acquire or dispose of it as he did[.]’ OCGA § 16-8-10(2). Therefore, robbery by intimidation, which is defined in and proscribed by OCGA § 16-8-40(a)(2), is not included in those crimes for which the ‘claim of right’ defense is available. In refusing to extend the defense to crimes other than traditional theft cases, we explained that ‘[t]o allow a “claim of right” defense to an offense, such as robbery by sudden snatching, within which the use of force is implicit would sanction the use of force to claim the property.’ Westmoreland v. State, 245 Ga.App. 482, 484(1), 538 S.E.2d 119 (2000). ‘In such an instance, the ends do not justify the means, regardless of whether the defendant thinks he has a right to the property.’ Crowder v. State, 241 Ga.App. 818, 820(2)(b), 527 S.E.2d 901 (2000) (claim of right defense not available for armed robbery).” Crowder v. State, 241 Ga.App. 818, 527 S.E.2d 901 (January 13, 2000). Convictions for voluntary manslaughter, armed robbery, and related offenses affirmed; “claim of right,” by statute, is a defense to theft, not armed robbery. “While we agree with Crowder that “ intent to commit a theft” is an essential element of armed robbery, we decline to judicially extend the defense of ‘claim of right’ to mitigate this essential element when the uncontradicted evidence shows a completed armed robbery. To do so would be to find that an alleged ‘claim of right’ justifies the use of a gun or other weapon to secure that claim. In such an instance, the ends do not justify the means, regardless of whether the defendant thinks he has a right to the property. Presumably, that is why the legislature did not include ‘claim of right’ as a defense to armed robbery.” Accord, Westmoreland v. State , 245 Ga.App. 482, 538 S.E.2d 119 (August 4, 2000) (claim of right not a defense to robbery by sudden snatching). I. COERCION Allen v. State, 296 Ga. 785, 770 S.E.2d 824 (March 27, 2015). Murder and related convictions affirmed; trial court properly didn’t charge jury on justification, based on defendant’s claim that “he feared for the lives of his family at the hands of [co-conspirator] Roberts if he did not do what Roberts wished, as well as his own life, and thus there was ‘evidence of “a threat of imminent death or great bodily injury to two or more people, which [he could] avoid only by killing one innocent person....” [Cit.]’ Gravitt, supra at 34, 608 S.E.2d 202. However, such a justification defense would not fall under the omnibus provision of OCGA § 16–3–20(6); under that provision, the asserted defense must ‘stand upon the same footing of reason and justice as those [defenses] enumerated’ in Title 16, Article 2, of the Code. And, to the extent that Allen claimed justification because of a threat to his family, such would not stand upon the same footing as the defenses so enumerated; the justification defenses enumerated in the Article that contemplate the use of force do so in the face of a current or imminent threat, see OCGA §§ 16–3–21; 16–323; 16–3–24; & 16–3–26, and there is no evidence that Roberts was in a position to harm Allen's family when Allen committed his acts.” Calmes v. State, 312 Ga.App. 769, 719 S.E.2d 516 (November 3, 2011). Convictions for armed robbery and related offenses affirmed; trial court properly declined to charge on coercion, as evidence didn’t support it. “Even assuming that