Patterson v. New York

Citation. 432 U.S. 197, 97 S. Ct. 2319, 53 L. Ed. 2d 281, 1977 U.S. 120.

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Citation432 U.S. 197, 97 S. Ct. 2319, 53 L. Ed. 2d 281, 1977 U.S. 120.

Brief Fact Summary. The Defendant, Gordon Patterson, Jr. (Defendant), killed the paramour of his estranged wife by shooting him twice in the head. The Defendant admitted to the killing, but raised the affirmative defense of extreme emotional disturbance, which he had the burden of proving at trial. The jury found him guilty of murder.

Synopsis of Rule of Law. Burdening a defendant with proving the affirmative defense of extreme emotional disturbance does not violate the Fourteenth Amendment to the United State Constitution’s (Constitution) Due Process Clause.

Points of Law - Legal Principles in this Case for Law Students.

Mullaney's holding, it is argued, is that the State may not permit the blameworthiness of an act or the severity of punishment authorized for its commission to depend on the presence or absence of an identified fact without assuming the burden of proving the presence or absence of that fact, as the case may be, beyond a reasonable doubt.

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Facts. The Defendant became estranged from his wife. She thereafter resumed an association with a neighbor, John Northrup (Northrup), to whom she had been engaged prior to her marriage to the Defendant. On the date in question, the Defendant borrowed a rifle and went to the residence of his father-in-law where he observed his wife through a window in a state of semiundress with Northrup. The Defendant entered the house and killed Northrup by shooting him twice in the head.

Issue. Does burdening the Defendant with proving the affirmative defense of extreme emotional disturbance violate the Due Process Clause of the Fourteenth Amendment of the Constitution?

Held. No. The Due Process Clause of the Constitution requires that the prosecution prove every element of the offense beyond a reasonable doubt, which the State did here. To require the prosecution to then disprove the non-existence of all mitigating circumstances would be “too cumbersome, too expensive, and too inaccurate.” Therefore, since nothing was presumed or implied against the Defendant and the prosecution proved every element of the crime beyond a reasonable doubt, the Due Process Clause of the Constitution is not violated in making the Defendant prove his affirmative defense by a preponderance of the evidence.

Dissent. The Due Process Clause of the Constitution dictates that the prosecution must bear the burden of proving the existence or absence of extreme emotional disturbance.

Discussion. The prosecution bears the burden of proving beyond a reasonable doubt only those elements of the offense charged. The Defendant must therefore prove any affirmative defenses.

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