People v. Patterson, 39 N.Y.2d 288 (1976)
A state may require a defendant to prove an affirmative defense, such as extreme emotional disturbance, to reduce a murder charge to manslaughter without violating due process, provided the state has already proven beyond a reasonable doubt every element of murder.
Summary
Gordon Patterson was convicted of murder. He argued that New York’s law, requiring him to prove he acted under extreme emotional disturbance to reduce the charge to manslaughter, violated due process under Mullaney v. Wilbur. The New York Court of Appeals upheld the conviction, distinguishing New York law from the Maine law in Mullaney. The Court reasoned that New York requires the prosecution to prove every element of murder beyond a reasonable doubt, including intent, and the affirmative defense of extreme emotional disturbance does not negate intent but offers a mitigating circumstance.
Facts
Gordon Patterson killed his wife’s lover, John Northrup, after finding them together in a state of undress. Patterson confessed to the killing. At trial, his defense was that the gun went off accidentally and, alternatively, that he acted under the influence of extreme emotional disturbance due to his unstable marriage and his wife’s infidelity.
Procedural History
The trial court instructed the jury that the prosecution had to prove intent to kill beyond a reasonable doubt, but Patterson had to prove his affirmative defense of extreme emotional disturbance by a preponderance of the evidence. The jury convicted Patterson of murder. The Appellate Division affirmed. Patterson appealed to the New York Court of Appeals, arguing that Mullaney v. Wilbur required the prosecution to disprove extreme emotional disturbance beyond a reasonable doubt.
Issue(s)
Whether New York’s homicide statutes, which require a defendant to prove the affirmative defense of extreme emotional disturbance to reduce a murder charge to manslaughter, violate the Due Process Clause of the Fourteenth Amendment.
Holding
No, because New York law requires the prosecution to prove every element of murder beyond a reasonable doubt, and the affirmative defense of extreme emotional disturbance does not negate any of those elements but rather offers a mitigating circumstance that justifies a lesser punishment.
Court’s Reasoning
The Court distinguished New York law from the Maine law struck down in Mullaney v. Wilbur. In Maine, malice aforethought was an element of murder, and the absence of heat of passion negated malice. Therefore, the state had to prove the absence of heat of passion beyond a reasonable doubt. In contrast, New York requires the prosecution to prove intent to kill beyond a reasonable doubt, and extreme emotional disturbance does not negate intent. Instead, it is a mitigating factor that explains the intentional act, rendering the defendant less culpable. The Court emphasized that New York has always defined murder and manslaughter as distinct offenses, with the prosecution bearing the burden to prove the elements of murder. “So long as the prosecution must prove, beyond a reasonable doubt, that the defendant intended to kill his victim, it is not a violation of due process to permit the defendant to establish he formulated his intent while ‘under the influence of extreme emotional disturbance.’” The court noted the evolution of the extreme emotional disturbance defense from the traditional “heat of passion” defense, explaining that the modern approach acknowledges that significant mental trauma can affect a defendant’s mind over a substantial period. The Court also stated, “Judicial opinions are not written and rendered in the abstract. Language is given its meaning by the context which compels its writing. It is basic to our common-law system that a court decides only the case before it.” Therefore, Mullaney, which dealt with Maine law, did not automatically invalidate New York’s distinct statutory scheme.