98 N.Y.2d 70 (2002)
A defendant is not entitled to a jury instruction on the affirmative defense of extreme emotional disturbance unless sufficient evidence is presented to support both the subjective element (that the defendant acted under the influence of extreme emotional disturbance) and the objective element (that there was a reasonable explanation or excuse for the disturbance).
Summary
Roche was convicted of second-degree murder for the stabbing death of his common-law wife. He appealed, arguing the trial court erred by not instructing the jury on the affirmative defense of extreme emotional disturbance (EED). The New York Court of Appeals reversed the Appellate Division’s order, holding that the evidence presented at trial was insufficient to warrant an EED charge. The Court clarified that both subjective (defendant’s mental state) and objective (reasonableness of the disturbance) elements must be supported by sufficient evidence, and the brutal nature of the crime alone is insufficient to establish EED. Defendant’s actions and statements before, during, and after the crime did not demonstrate the required loss of self-control or mental infirmity.
Facts
Lillian Rivera was found stabbed to death in her apartment, which she shared with Roche. Roche told neighbors Rivera had killed herself. He also told another acquaintance, Bell, that he killed Rivera because she was “going crazy.” Roche changed his story multiple times, initially claiming his wife had committed suicide. At no point did he claim to have lost control or been mentally disturbed at the time of the killing. The defense focused on the theory that someone else committed the murder.
Procedural History
Roche was convicted of second-degree murder in the first trial; this was reversed on appeal due to an improper jury charge. At the second trial, Roche requested the judge instruct the jury on the lesser included offense of manslaughter based on extreme emotional disturbance. The trial court denied this request. The jury again convicted Roche of second-degree murder. The Appellate Division reversed, finding the trial court should have instructed the jury on the affirmative defense of extreme emotional disturbance. The People appealed to the New York Court of Appeals.
Issue(s)
Whether the trial court erred in failing to instruct the jury on the affirmative defense of extreme emotional disturbance, where the defendant was charged with second-degree murder in connection with the stabbing death of his wife.
Holding
No, because the evidence presented at trial was insufficient to support either the subjective or objective elements of the extreme emotional disturbance defense.
Court’s Reasoning
The Court of Appeals held that a defendant is entitled to an extreme emotional disturbance charge only when sufficient evidence supports both elements of the defense. The subjective element requires evidence that the defendant acted under the influence of extreme emotional disturbance, typically shown by a loss of self-control due to a mental infirmity not rising to the level of insanity. The objective element requires a reasonable explanation or excuse for the disturbance, viewed from the defendant’s perspective at the time. The Court found no evidence that Roche suffered from a mental infirmity or loss of self-control during the stabbing. His actions after the crime (attempting to conceal evidence, fabricating a suicide story) indicated a calculated effort to avoid responsibility, not a disturbed state of mind. The Court stated, “Defendant cannot rely on his statements to the police to establish the presence of an extreme emotional disturbance since he asserted that he had not harmed his wife in any respect.” The Court rejected the argument that the brutality of the crime, alone, indicated an extreme emotional disturbance. While the nature of the wounds can be relevant, it must be linked to other compelling evidence of emotional disturbance. “Where we have referenced the nature or severity of the wounds, the probative value of such evidence has been linked to other compelling evidence of extreme emotional disturbance.” The Court concluded that the arguments and errands cited by the defense were insufficient to constitute a reasonable explanation or excuse for extreme emotional disturbance.