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.
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.View Full Point of Law
Issue. Does it violate the Due Process Clause to place the burden on Defendant to prove severe emotional disturbance?
Held. 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.
Dissent. 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.
Discussion. 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.