People v. Haney, 66 N.Y.2d 85 (1985)

A defendant is entitled to a jury instruction on the affirmative defense of extreme emotional disturbance when sufficient evidence is presented for a jury to find, by a preponderance of the evidence, that the defendant acted under the influence of extreme emotional disturbance and that there was a reasonable explanation or excuse for the disturbance.

Summary

Haney was convicted of second-degree murder. The Court of Appeals reversed, holding that the trial court erred in refusing to charge the jury on the affirmative defense of extreme emotional disturbance. The court found that Haney’s statements about “snapping” after the victim ridiculed his impotence, coupled with the gruesome nature of the crime, provided sufficient evidence for a jury to find both subjective (acting under extreme emotional disturbance) and objective (reasonable explanation for the disturbance) elements of the defense. This case highlights the evidentiary threshold for submitting an affirmative defense to the jury.

Facts

Gloria Blocken was found dead, decapitated and eviscerated, in her apartment. Haney admitted to police that he killed Blocken after attempting to have sexual intercourse with her and failing. He stated that she began laughing at him, despite his requests for her to stop. He then slashed her across the chest with a knife and continued slashing, eventually decapitating her. Haney told an Assistant District Attorney that after drinking, he became angry when Blocken ridiculed his impotence, stating that something