Wednesday, February 27, 2013

Patterson v. New York case brief

Patterson v. New York case brief summary
432 U.S. 197
SYNOPSIS: Defendant sought certiorari review of a judgment of the Court of Appeals of New York, which affirmed his trial court murder conviction and which held that New York's murder statute, N.Y. Penal Law § 125.25 (1975), was consistent with due process.

FACTS: Defendant was charged with second-degree murder under N.Y. Penal Law § 125.25 (1975) for killing his estranged wife's friend. After defendant was convicted of murder, he appealed the verdict on the basis that the need to prove the affirmative defense of extreme emotional disturbance was a violation of the Fourteenth Amendment.

HOLDING:
Affirming the appeals court and the trial court, the Court held that there was no violation of defendant's due process rights.

ANALYSIS:
Defendant had the burden of proving the affirmative defense of extreme emotional disturbance by a preponderance of the evidence. Under prior cases, this was not a constitutional violation. The Court concluded first that facts constituting a crime had to be established by the State beyond a reasonable doubt, based on all the evidence including the evidence of defendant's mental state. Then, the State was permitted to refuse to sustain the affirmative defense of insanity, or in this case emotional disturbance, unless defendant established the defense by a preponderance of the evidence.

OUTCOME: The Court affirmed the judgment.

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