Patterson v. New York

Supreme Court of United States
432 U.S. 197 (1977)

ELI5:

Rule of Law:

The Due Process Clause of the Fourteenth Amendment does not prohibit a state from placing the burden of persuasion on a defendant for an affirmative defense that mitigates culpability, so long as the affirmative defense does not serve to negate any of the elements of the crime which the prosecution must prove beyond a reasonable doubt.

Facts:

Gordon Patterson, Jr. and his wife, Roberta, were estranged after a brief and unstable marriage.
Roberta resumed her association with John Northrup, a neighbor to whom she was previously engaged.
On December 27, 1970, Patterson borrowed a rifle from an acquaintance.
Patterson went to his father-in-law's residence, where he observed Roberta and Northrup together through a window, with Roberta in a state of semiundress.
Patterson entered the house and killed Northrup by shooting him twice in the head.
Prior to trial, Patterson confessed to killing Northrup.
At trial, Patterson raised the defense that he acted under the influence of extreme emotional disturbance.

Procedural Posture:

Gordon Patterson, Jr. was charged with second-degree murder in a New York state trial court.
The jury, instructed that Patterson bore the burden of proving his affirmative defense of extreme emotional disturbance, found him guilty of murder.
Patterson appealed, and the Appellate Division of the New York Supreme Court, an intermediate appellate court, affirmed the conviction.
Patterson then appealed to the New York Court of Appeals, the state's highest court, which also affirmed the conviction.
The United States Supreme Court noted probable jurisdiction to consider Patterson's appeal.

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Issue:

Does a New York law that requires a defendant charged with second-degree murder to prove the affirmative defense of 'extreme emotional disturbance' by a preponderance of the evidence in order to reduce the charge to manslaughter violate the Due Process Clause of the Fourteenth Amendment?

Opinions:

Majority - Justice White

No. The New York law does not violate the Due Process Clause. A state may constitutionally place the burden of proving an affirmative defense on the defendant if that defense does not negate an essential element of the crime itself. New York defines second-degree murder as the (1) intent to cause the death of another person and (2) causing that death. The prosecution successfully proved both of these elements beyond a reasonable doubt. The affirmative defense of extreme emotional disturbance does not negate intent or causation; rather, it is a separate issue of mitigation that, if proven by the defendant, reduces the crime to manslaughter. This allocation of the burden of proof is consistent with historical practice and prior precedents like Leland v. Oregon, which allowed states to require defendants to prove insanity. Unlike the law in Mullaney v. Wilbur, which required the defendant to disprove malice aforethought (an element of murder in Maine), New York's law does not presume any element of the crime against the defendant. Therefore, the state satisfied its constitutional obligation under In re Winship by proving all elements of the defined offense, and it was permissible to require Patterson to bear the burden of proving his mitigating circumstance.

Dissenting - Justice Powell

Yes. The New York law violates the Due Process Clause. The distinction the majority draws between New York's 'extreme emotional disturbance' defense and Maine's 'heat of passion' defense struck down in Mullaney v. Wilbur is purely formalistic and ignores the functional reality. The presence or absence of extreme emotional disturbance is the single most critical factor distinguishing murder from manslaughter in New York, just as heat of passion was in Maine. The Court's holding allows a state to evade the constitutional requirements of In re Winship through clever statutory draftsmanship, simply by defining a crime narrowly and recasting traditional elements of culpability as affirmative defenses. The Due Process Clause is concerned with substance, not form, and the effect on the defendant is identical in both cases: he is required to disprove a critical fact that determines the degree of his culpability and the severity of his punishment. This approach drains Winship of its vitality and abdicates the Court's responsibility to protect the presumption of innocence.

Analysis:

This decision significantly limited the scope of Mullaney v. Wilbur and clarified that the Winship 'beyond a reasonable doubt' standard applies only to the facts included in the legislative definition of a crime. By endorsing a formalistic approach, the Court granted state legislatures substantial discretion to allocate the burden of proof for mitigating factors by labeling them as affirmative defenses. This ruling has had a lasting impact, solidifying the framework for affirmative defenses in criminal law and influencing how states draft criminal statutes to balance prosecutorial burdens with defendants' rights.

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