State v. Elliott
1979 Conn. LEXIS 694, 411 A.2d 3, 177 Conn. 1 (1979)
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Rule of Law:
The affirmative defense of 'extreme emotional disturbance' is a significantly broader concept than the common law 'heat of passion' defense, as it does not require a sudden provoking event or an immediate homicidal act, but can arise from a gradual accumulation of mental trauma causing the defendant to brood over time.
Facts:
- Robert L. Elliott had a history of conflict with his brother, the victim, and harbored an overwhelming fear of him, referring to him as a 'ranger killer.'
- In a prior incident, Elliott's brother chased him with a tire iron, which was so frightening it caused Elliott to leave the area for several years.
- A psychiatrist testified that at the time of the shooting, Elliott was suffering from the combined stress of child custody problems, financial difficulties, and his long-standing fear of his brother.
- On the morning of June 22, 1976, Elliott, armed with a loaded revolver, forced his way into his brother's home.
- Inside, Elliott threatened his ten-year-old niece and pursued his brother's wife down a hallway while pointing the gun at her.
- When his brother appeared from behind him and called his name, Elliott turned and shot him twice in rapid succession, killing him.
Procedural Posture:
- A grand jury indicted Robert L. Elliott for the crime of murder.
- The case was tried before a jury in a Connecticut trial court.
- At trial, the defendant raised the affirmative defense of extreme emotional disturbance.
- The jury returned a verdict finding the defendant guilty of murder as charged.
- The trial court entered a judgment of conviction and sentenced the defendant to not less than twenty-five years to life imprisonment.
- The defendant appealed the judgment to the Supreme Court of Connecticut, assigning as error the trial court's jury charge on extreme emotional disturbance.
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Issue:
Does a jury instruction that defines the statutory defense of 'extreme emotional disturbance' using the narrower, traditional elements of the common law 'heat of passion' defense constitute a reversible error?
Opinions:
Majority - Loiselle, J.
Yes. A jury instruction that conflates the defense of extreme emotional disturbance with the heat of passion defense is erroneous because the modern statutory defense is a considerably expanded version of its common law predecessor. The trial court incorrectly instructed the jury using the substance of the traditional 'heat of passion' charge, which requires a sudden provocation and no time for the 'blood to cool.' The court reasoned that the 'extreme emotional disturbance' defense, adopted from the Model Penal Code, does not require a specific triggering event and can be the result of a significant mental trauma that caused the defendant to brood for a long period before reacting violently. The standard for reasonableness is also different; it must be determined from the viewpoint of a person in the defendant’s situation under the circumstances as the defendant subjectively believed them to be. Because the trial court's charge was too narrow and did not reflect the expanded scope of the statute, it was an error requiring a new trial.
Analysis:
This case is significant for formally distinguishing the modern statutory defense of 'extreme emotional disturbance' from the older common law 'heat of passion' defense in Connecticut. By adopting a standard that considers the defendant's subjective viewpoint and allows for a defense based on long-term mental trauma rather than just sudden rage, the court broadens the availability of this mitigating defense. This decision aligns Connecticut law with the Model Penal Code and influential jurisdictions like New York, establishing a clearer, more defendant-friendly framework for reducing a murder charge to manslaughter. Future cases must now instruct juries using a test that assesses the reasonableness of the defendant's emotional state from their unique perspective and circumstances.
