Citation. 432 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.
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?