State v. Elliott
177 Conn. 1, 1979 Conn. LEXIS 694, 411 A.2d 3 (1979)
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Rule of Law:
The affirmative defense of 'extreme emotional disturbance' (EED) is a significantly expanded version of the common law 'heat of passion' defense. EED does not require a sudden provoking event or an immediate homicidal act, but can arise from a significant mental trauma that caused the defendant to brood over time before reacting violently.
Facts:
- Robert L. Elliott had a history of conflict with his brother, the victim, which resulted in Elliott developing an overwhelming fear of him.
- In addition to the fear of his brother, Elliott was experiencing significant stress from child custody problems and the financial strain of maintaining a home.
- On the morning of June 22, 1976, Elliott went to his brother's home armed with a loaded revolver.
- He forced his way into the house, threatened his ten-year-old niece with the gun, and pursued his brother's wife down a hallway while pointing the gun at her.
- When his brother came up from behind him and called out his name, Elliott turned around and shot his brother twice, killing him.
- A psychiatrist testified that at the time of the shooting, Elliott was acting under the influence of an extreme emotional disturbance caused by the combination of his overwhelming fear of his brother and other life stressors.
Procedural Posture:
- A grand jury indicted the defendant, Robert L. Elliott, for murder.
- The case was tried before a jury in a state trial court.
- At trial, Elliott raised the affirmative defense of extreme emotional disturbance to mitigate the murder charge.
- The jury returned a verdict finding Elliott guilty of murder.
- The trial court entered a judgment on the verdict and sentenced Elliott to a term of not less than twenty-five years to life imprisonment.
- Elliott appealed the judgment to the state's highest court, arguing that the trial court erred in its jury instruction on the defense of extreme emotional disturbance.
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Issue:
Did the trial court err by instructing the jury on the defense of extreme emotional disturbance using the traditional legal standard for the 'heat of passion' defense?
Opinions:
Majority - Loiselle, J.
Yes, the trial court erred by giving a jury instruction that improperly conflated the modern statutory defense of extreme emotional disturbance with the narrower, traditional 'heat of passion' defense. The defense of extreme emotional disturbance under General Statutes § 53a-54a(a) is substantially different and broader than the common law doctrine. The court's reasoning is that the statute, modeled after the Model Penal Code and a similar New York statute, does not require a sudden 'provoking or triggering event' or that the killing occur in 'hot blood.' Instead, it allows for a defense where a defendant experienced a significant mental trauma, brooded over it for a long period, and then reacted violently. The trial court's charge, which required a 'sudden frenzy of passion' and considered whether the defendant's 'blood had time to cool,' improperly narrowed the scope of the defense and constituted a legal error.
Analysis:
This decision formally distinguishes the modern statutory defense of extreme emotional disturbance from the older, more restrictive common-law 'heat of passion' doctrine in Connecticut. It establishes that EED is a broader, more subjective defense that can mitigate murder to manslaughter even if the defendant's emotional state developed over a long period rather than in a sudden burst of rage. By adopting a specific test, the court provides clear guidelines for trial courts on how to instruct juries, thereby standardizing the application of the EED defense and recognizing that prolonged mental trauma can be a mitigating factor in homicide cases.
