New York Law Review

Tag: People v. Patterson

  • People v. Patterson, 78 N.Y.2d 711 (1991): Suppression of Evidence After CPL 160.50 Violation

    78 N.Y.2d 711 (1991)

    A violation of CPL 160.50, which mandates the return of photographs and sealing of records after a criminal case is favorably terminated, does not automatically require suppression of otherwise admissible identification testimony in a subsequent, unrelated criminal proceeding.

    Summary

    Charles Patterson appealed his robbery conviction, arguing that the in-court identification should have been suppressed because it stemmed from a photo array that used a photograph taken during a prior, dismissed charge, violating CPL 160.50. The New York Court of Appeals affirmed the conviction, holding that while the use of the photograph was a statutory violation, it did not infringe upon any constitutional right and did not warrant suppression of the identification testimony, absent any claim that the identification procedure itself was impermissibly suggestive. The Court emphasized that CPL 160.50 aims to protect against stigma and discrimination, not to create a constitutionally derived right affecting the reliability of evidence in subsequent cases.

    Facts

    Michael Hagenbach was robbed and assaulted. He identified Charles Patterson as one of his assailants from a photo array. The photograph of Patterson used in the array was taken in connection with a prior, unrelated criminal charge against Patterson that had been dismissed. An order was issued to seal the case file pursuant to CPL 160.50. Despite the sealing order, the police used Patterson’s photograph in the photo array approximately two months later.

    Procedural History

    Patterson was convicted of second-degree robbery. He moved to suppress the in-court identification testimony based on the CPL 160.50 violation, but the trial court denied the motion. The Appellate Division affirmed the conviction, holding that the use of the photograph did not require per se suppression of the identification testimony. Patterson appealed to the New York Court of Appeals.

    Issue(s)

    1. Whether the use of a photograph retained in violation of CPL 160.50 in a photo array requires suppression of subsequent in-court identification testimony in an unrelated criminal proceeding.

    2. Whether the trial evidence was legally sufficient to support Patterson’s conviction for robbery.

    Holding

    1. No, because the violation of CPL 160.50, without more, does not infringe upon a constitutional right and does not automatically warrant suppression of otherwise reliable identification testimony.

    2. Yes, because the evidence, viewed in the light most favorable to the prosecution, provided a sufficient basis for the jury to conclude that Patterson forcibly deprived Hagenbach of his truck and caused him physical injury.

    Court’s Reasoning

    The Court reasoned that CPL 160.50 was enacted to protect individuals against whom criminal charges were brought but not sustained, aiming to remove the stigma associated with an accusation. While the statute was violated, the violation did not implicate any constitutional right related to the reliability of the identification process. The Court distinguished this case from those where suppression was warranted due to violations of statutes directly linked to constitutional rights, such as Fourth Amendment protections. The Court noted that the legislature provided a civil remedy for CPL 160.50 violations under the Executive Law, indicating that the statute’s primary purpose was not to create a constitutional right enforceable through the exclusionary rule. The Court stated, “[T]he legislative objective was to remove any ‘stigma’ flowing from an accusation of criminal conduct terminated in favor of the accused, thereby affording protection (i.e., the presumption of innocence) to such accused in the pursuit of employment, education, professional licensing and insurance opportunities.”

    The dissent argued that CPL 160.50 protects a “substantial right” closely related to Fourth Amendment protections and the presumption of innocence. It asserted that suppression is an appropriate remedy for statutory violations that implicate constitutional guarantees and that the majority’s decision undermines the deterrent effect of CPL 160.50 and law enforcement’s compliance with it. The dissent argued that CPL 160.50 was designed to protect “reputation and privacy interests by controlling the physical location of the photographs and fingerprints.”

  • People v. Patterson, 39 N.Y.2d 288 (1976): Affirmative Defenses and Due Process in Murder Cases

    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.