Patterson v. New York

53 L. Ed. 2d 281 · Supreme Court of the United States · 1977

Facts

After a brief and unstable marriage, Gordon Patterson, Jr. became estranged from his wife, Roberta. Roberta resumed an association with John Northrup, her former fiancé. On December 27, 1970, Patterson borrowed a rifle and went to his father-in-law's residence. There, he observed his wife and Northrup through a window in a state of semiundress. Patterson entered the house and killed Northrup by shooting him twice in the head. Patterson was charged with second-degree murder, which in New York requires intent to cause death and causing death. New York law also permits an affirmative defense of extreme emotional disturbance to reduce murder to manslaughter.

Procedural history

Patterson was found guilty of murder by a jury. The Appellate Division affirmed the conviction. While his appeal was pending before the New York Court of Appeals, the U.S. Supreme Court decided Mullaney v. Wilbur. The New York Court of Appeals rejected Patterson's argument that New York's statute was unconstitutional under Mullaney, holding it consistent with due process. Patterson then appealed to the U.S. Supreme Court, which noted probable jurisdiction.

Issue

Is it constitutional under the Fourteenth Amendment's Due Process Clause for New York State to burden a defendant in a murder trial with proving the affirmative defense of extreme emotional disturbance?

Holding

Yes, New York's law requiring the defendant to prove the affirmative defense of extreme emotional disturbance by a preponderance of the evidence is constitutional. The Court affirmed Patterson's conviction, finding it did not violate due process.

Rule

The Due Process Clause requires the prosecution to prove beyond a reasonable doubt every fact necessary to constitute the crime charged. However, it does not require the state to disprove beyond a reasonable doubt every fact constituting an affirmative defense that mitigates culpability or punishment, provided the defense does not negate an element of the crime. States may allocate the burden of proving such affirmative defenses, like extreme emotional disturbance, to the defendant by a preponderance of the evidence, consistent with Leland v. Oregon and Rivera v. Delaware.

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