Patterson v. New York
Encyclopedia
Patterson v. New York, 432 U.S. 197
(1977), is a legal case
heard by the United States Supreme Court regarding the constitutionality under the Fourteenth Amendment
's Due Process Clause of burdening a defendant with proving the affirmative defense of extreme emotional disturbance as defined by New York law.
Patterson was charged with second-degree murder. In New York, there were two elements of this crime: (1) "intent to cause the death of another person"; and (2) "causing the death of such person or of a third person." - N.Y. Penal Law. Malice aforethought is not an element of the crime. The State of New York allowed a person accused of murder to raise an affirmative defense that he "acted under the influence of extreme emotional disturbance for which there was a reasonable explanation or excuse."
The New York law required that the defendant in this and any prosecution for second-degree murder prove by a preponderance of the evidence the affirmative defense of extreme emotional disturbance in order to reduce the crime to manslaughter.
A trial court jury found Patterson guilty for murder. On appeal, the New York Court of Appeals found the law (and verdict) not to violate Patterson's Constitutional rights as guaranteed under the Due Process Clause of the Fourteenth Amendment.
The case was appealed to the US Supreme Court. It was argued March 1, 1977 and decided June 17, 1977
Victor Rubino argued the cause for appellant. With him on the briefs was Betty Friedlander. John Finnerty argued the cause for appellee. With him on the brief was Alan Marrus.
in which Justice Warren E. Burger
, Justice Potter Stewart
, Justice Harry Blackmun
and Justice John Paul Stevens
joined. Justice Lewis F. Powell, Justice William J. Brennan and Justice Thurgood Marshall
dissented. Justice William Rehnquist
took no part in the consideration or the decision of the case.
The Court decided that shifting the burden of proof to the Defendant of a mitigating circumstance affirmative defense does not violate the Due Process Clause of the U.S. Constitution.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1977), is a legal case
Legal case
A legal case is a dispute between opposing parties resolved by a court, or by some equivalent legal process. A legal case may be either civil or criminal...
heard by the United States Supreme Court regarding the constitutionality under the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
's Due Process Clause of burdening a defendant with proving the affirmative defense of extreme emotional disturbance as defined by New York law.
Background
After a brief and unstable marriage, the appellant, Gordon Patterson, Jr., became estranged from his wife, Roberta. Roberta resumed an association with John Northrup, a neighbor to whom she had been engaged prior to her marriage to appellant. On December 27, 1970, Patterson borrowed a rifle from an acquaintance and went to the residence of his father-in-law. There, he observed his wife through a window in a state of semiundress in the presence of John Northrup. He entered the house and killed Northrup by shooting him twice in the head.Patterson was charged with second-degree murder. In New York, there were two elements of this crime: (1) "intent to cause the death of another person"; and (2) "causing the death of such person or of a third person." - N.Y. Penal Law. Malice aforethought is not an element of the crime. The State of New York allowed a person accused of murder to raise an affirmative defense that he "acted under the influence of extreme emotional disturbance for which there was a reasonable explanation or excuse."
The New York law required that the defendant in this and any prosecution for second-degree murder prove by a preponderance of the evidence the affirmative defense of extreme emotional disturbance in order to reduce the crime to manslaughter.
A trial court jury found Patterson guilty for murder. On appeal, the New York Court of Appeals found the law (and verdict) not to violate Patterson's Constitutional rights as guaranteed under the Due Process Clause of the Fourteenth Amendment.
The case was appealed to the US Supreme Court. It was argued March 1, 1977 and decided June 17, 1977
Victor Rubino argued the cause for appellant. With him on the briefs was Betty Friedlander. John Finnerty argued the cause for appellee. With him on the brief was Alan Marrus.
The Decision
Affirmed. The decision was delivered by Justice Byron WhiteByron White
Byron Raymond "Whizzer" White won fame both as a football halfback and as an associate justice of the Supreme Court of the United States. Appointed to the court by President John F. Kennedy in 1962, he served until his retirement in 1993...
in which Justice Warren E. Burger
Warren E. Burger
Warren Earl Burger was the 15th Chief Justice of the United States from 1969 to 1986. Although Burger had conservative leanings, the U.S...
, Justice Potter Stewart
Potter Stewart
Potter Stewart was an Associate Justice of the United States Supreme Court. During his tenure, he made, among other areas, major contributions to criminal justice reform, civil rights, access to the courts, and Fourth Amendment jurisprudence.-Education:Stewart was born in Jackson, Michigan,...
, Justice Harry Blackmun
Harry Blackmun
Harold Andrew Blackmun was an Associate Justice of the Supreme Court of the United States from 1970 until 1994. He is best known as the author of Roe v. Wade.- Early years and professional career :...
and Justice John Paul Stevens
John Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
joined. Justice Lewis F. Powell, Justice William J. Brennan and Justice Thurgood Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
dissented. Justice William Rehnquist
William Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
took no part in the consideration or the decision of the case.
The Court decided that shifting the burden of proof to the Defendant of a mitigating circumstance affirmative defense does not violate the Due Process Clause of the U.S. Constitution.