Citation. Patterson v. New York, 432 U.S. 197, 97 S. Ct. 2319, 53 L. Ed. 2d 281, 1977)
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Brief Fact Summary.
Defendant, Gordon Patterson, was convicted of second-degree murder after killing his estranged wife’s boyfriend. He went to the victim’s house with a gun, and upon seeing his wife partially undressed with the victim, he shot the victim twice in the head.
Synopsis of Rule of Law.
The State is required to prove all elements of a crime beyond a reasonable doubt, and placing any of that burden on a defendant would violate the Due Process Clause.
Gordon Patterson, Defendant, became estranged from his wife, Roberta. Roberta began a relationship with John Northrup. She had been engaged to Northrup prior to marrying Defendant. Defendant shot and killed Northup after going to his father-in-law’s house and seeing Roberta partially undressed with Northrup. Defendant was charged and found guilty of second-degree murder. Defendant confessed to the killing but raised a defense of “extreme emotional disturbance. The jury was instructed that Defendant had the burden of proving his affirmative defense by a preponderance of the evidence.
Does it violate the Due Process Clause to place the burden on Defendant to prove severe emotional disturbance?
Justice White issued the opinion for the United States Supreme Court in affirming the conviction and holding that the burden placed on Defendant did not violate due process.
Justice Powell, joined by Justices Brennan and Marshall, issued a dissenting opinion arguing that the ruling leaves room for legislative abuses shifting the burden on certain elements to defendants when it should be with the State.
The preponderance of the evidence standard on the emotional distress issue does not constitute a separate element of the crime. The burden for proving all elements of murder in this case still lies with the State, and require them to be proved beyond a reasonable doubt. The State is not and should not be required to prove that potentially mitigating circumstance are not present in any given case.