People v. Patterson
NY2d 288 (1977)
Rule of Law:
A state law requiring a defendant in a murder prosecution to prove the affirmative defense of extreme emotional disturbance by a preponderance of the evidence does not violate the Due Process Clause, so long as the prosecution is still required to prove every element of the crime of murder, including intent, beyond a reasonable doubt.
Facts:
- Gordon Patterson and his wife, Roberta Patterson, had a highly unstable marital relationship.
- Roberta left Gordon and initiated divorce proceedings.
- Roberta resumed a romantic relationship with a neighbor, John Northrup, to whom she had previously been engaged.
- On December 27, 1970, Gordon Patterson borrowed a rifle and went to his father-in-law's residence.
- Patterson observed his wife in a state of semiundress in the presence of John Northrup.
- Upon seeing them, Patterson entered the house and shot Northrup twice in the head, killing him.
- After the shooting, Patterson confessed to the killing.
Procedural Posture:
- Gordon Patterson was indicted for the crime of murder in Steuben County, New York.
- At trial in the county court, the judge instructed the jury that the prosecution must prove intent to kill beyond a reasonable doubt, but that Patterson bore the burden of proving the affirmative defense of extreme emotional disturbance by a preponderance of the evidence.
- The jury convicted Patterson of murder.
- Patterson, as appellant, appealed the conviction to the Appellate Division of the Supreme Court of New York.
- The Appellate Division unanimously affirmed the trial court's judgment.
- Patterson, as appellant, was granted leave to appeal to the Court of Appeals of New York, the state's highest court.
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Issue:
Does a New York statute that requires a defendant in a murder prosecution to prove the affirmative defense of acting under the influence of extreme emotional disturbance by a preponderance of the evidence violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Jasen, J.
No. The New York statute placing the burden of proving extreme emotional disturbance on the defendant does not violate the Due Process Clause. Unlike the Maine statute struck down in Mullaney v. Wilbur, New York law requires the prosecution to prove beyond a reasonable doubt all elements of the crime of murder, including that the defendant acted with the intent to kill. The affirmative defense of extreme emotional disturbance does not serve to negate the element of intent; rather, it offers a mitigating circumstance that explains why the defendant acted intentionally but suggests he is less culpable. Because the defense is collateral to the elements of the crime itself, shifting the burden of persuasion to the defendant for this mitigating factor is constitutionally permissible.
Dissenting - Cooke, J.
Yes. The New York statutory scheme is functionally identical to the one found unconstitutional in Mullaney v. Wilbur and therefore violates due process. The presence or absence of extreme emotional disturbance is the sole factor that distinguishes murder from manslaughter and a life sentence from a 25-year sentence. By requiring the defendant to prove this critical fact, the statute unconstitutionally relieves the prosecution of its burden to prove beyond a reasonable doubt every fact necessary for a murder conviction. The distinction between 'heat of passion' in the Maine statute and 'extreme emotional disturbance' in the New York statute is semantic, not substantive.
Concurring - Breitel, C.J.
No. The majority opinion is correct, and it is important to recognize the salutary purpose of affirmative defenses in modern criminal law. They allow for a more nuanced gradation of offenses by giving a defendant the opportunity to prove mitigating circumstances that can reduce the severity of the crime. Placing the burden of proof on the defendant for such defenses is fair, particularly when the defendant has better access to the relevant evidence, and it encourages legislatures to create more sophisticated and just criminal statutes rather than overly broad ones.
Concurring - Jones, J.
No. While the Supreme Court's opinion in Mullaney could be interpreted to invalidate New York's statute, its application is not free from doubt. In the face of this ambiguity, judicial restraint is appropriate. The court should not strike down a carefully considered state legislative enactment until there is an explicit, unavoidable mandate from the Supreme Court to do so.
Analysis:
This case significantly clarified the scope of the Supreme Court's ruling in Mullaney v. Wilbur. It established that the constitutionality of placing the burden of proof on a defendant for an affirmative defense hinges on whether that defense negates an essential element of the charged crime. By holding that New York's 'extreme emotional disturbance' defense was a mitigating circumstance rather than a negation of intent, the court preserved the ability of states to use such affirmative defenses. This decision provided a constitutional framework for modern penal codes that seek to graduate culpability based on factors like mental state, solidifying the role of affirmative defenses in criminal law.
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