Summary of Patterson v. New York, S. Ct. U.S. 1977

Criminal

Facts: Patterson became estranged from his wife, who promptly returned to her former partner, Northrup, who lived next door. Patterson borrowed a gun and went to his father-in-law’s house where after seeing his wife semiclad and with Northrup he shot Northrup twice in the head.

Issue: Does the 14^th Amendment unconstitutionally burden the defendant with the requirement of proving his affirmative defense?

Holding: Proof of nonexistence of all affirmative defenses is not constitutionally required, only the elements of the offense beyond a reasonable doubt.

Procedure:  Trial court jury returned a verdict of guilty for murder.  On appeal to the NY Ct of Appeals that court found the verdict consistent with due process.  S. Ct. U.S. affirmed.

Rule:  1) Intent to cause the death of another person; and 2) causing the death of such person or of a third person.  NY allows a defendant to raise an affirmative defense that he “acted under the influence of extreme emotional disturbance for which there was a reasonable explanation or excuse.”

Reasoning: The due process clause does not put NY to the choice of abandoning those defenses or undertaking to disprove their existence in order to convict for a crime which otherwise is within its constitutional powers to sanction.

The crime of murder is defined * * * as causing the death of another person with the intent to do so.  The death, the intent to kill, and causation are the facts that the State is required to prove beyond a reasonable doubt for murder.  The statute does not provide an affirmative defense which if proven, would reduce the crime to manslaughter.  The facts were proven beyond a reasonable doubt and the evidence failed to persuade the jury as to Patterson’s affirmative defense.