Patterson v. New York

Patterson v. New York, 432 U.S. 197 (1977), is a legal case heard by the United States Supreme Court regarding the constitutionality under the Fourteenth Amendment's Due Process Clause of burdening a defendant with proving the affirmative defense of extreme emotional disturbance as defined by New York law.

Patterson v. New York
Argued March 1, 1977
Decided June 17, 1977
Full case namePatterson v. New York
Citations432 U.S. 197 (more)
97 S. Ct. 2319, 53 L. Ed. 2d 281, 1977 U.S. LEXIS 120
Holding
Shifting the burden of proof to the Defendant of a mitigating circumstance affirmative defense does not violate the Due Process Clause of the U.S. Constitution.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Potter Stewart
Byron White · Thurgood Marshall
Harry Blackmun · Lewis F. Powell Jr.
William Rehnquist · John P. Stevens
Case opinions
MajorityWhite, joined by Burger, Stewart, Blackmun, Stevens
DissentPowell, joined by Brennan, Marshall
Rehnquist took no part in the consideration or decision of the case.
Laws applied
U.S. Const. Amend. XIV

The court found that the State of New York had reclassified provocation ("extreme emotional disturbance") as an excuse (an affirmative defense requiring proof by preponderance of the evidence), rather than a circumstance negating the mental element (mens rea) which the prosecution had to prove beyond a reasonable doubt, as was the situation in Mullaney v. Wilbur (1975).[1]:18

Background

During his brief and unstable marriage, the appellant, Gordon Patterson, Jr., became estranged from his wife, Roberta. Roberta resumed an association with John Northrup, a neighbor to whom she had been engaged prior to her marriage to appellant. On December 27, 1970, Patterson borrowed a rifle from an acquaintance and went to the residence of his father-in-law. There, he observed his wife through a window in a state of semiundress in the presence of John Northrup. He entered the house and killed Northrup by shooting him twice in the head.

Patterson was charged with second-degree murder. In New York, there were two elements of this crime: (1) "intent to cause the death of another person"; and (2) "causing the death of such person or of a third person." – N.Y. Penal Law. Malice aforethought is not an element of the crime. The State of New York allowed a person accused of murder to raise an affirmative defense that he "acted under the influence of extreme emotional disturbance for which there was a reasonable explanation or excuse."

The New York law required that the defendant in this and any prosecution for second-degree murder prove by a preponderance of the evidence the affirmative defense of extreme emotional disturbance in order to reduce the crime to manslaughter.

A trial court jury found Patterson guilty for murder. On appeal, the New York Court of Appeals found the law (and verdict) not to violate Patterson's Constitutional rights as guaranteed under the Due Process Clause of the Fourteenth Amendment.

The case was appealed to the US Supreme Court. It was argued March 1, 1977 and decided June 17, 1977

Victor Rubino argued the cause for appellant. With him on the briefs was Betty Friedlander. John Finnerty argued the cause for appellee. With him on the brief was Alan Marrus.

The decision

Affirmed.

The Court decided that shifting the burden of proof to the Defendant of a mitigating circumstance affirmative defense does not violate the Due Process Clause of the U.S. Constitution.

See also

Further reading
  • Goldwag, Celia (1978). "The Constitutionality of Affirmative Defenses after Patterson v. New York". Columbia Law Review. Columbia Law Review Association, Inc. 78 (3): 655–678. doi:10.2307/1122046. JSTOR 1122046.
  • Sullivan, T. V. (1978). "Burdens of Persuasion in Criminal Proceedings: The Reasonable Doubt Standard after Patterson v. New York". University of Florida Law Review. 31 (2): 385–417.

References
  1. Criminal Law - Cases and Materials, 7th ed. 2012, Wolters Kluwer Law & Business; John Kaplan, Robert Weisberg, Guyora Binder, ISBN 978-1-4548-0698-1,
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