Patterson v. New York Case Brief

Why is the case important?

Appellant was charged with and convicted of the second-degree murder of his estranged wife’s boyfriend. Under New York law, the state permits a person to raise an affirmative defense that he “acted under the influence of extreme emotional disturbance.” The defendant bears the burden of persuasion by a preponderance of the evidence. Appellant sought to invalidate the statutory scheme by claiming it violated due process because it improperly shifted the burden of persuasion from the prosecutor to the defendant.

Facts of the case

Question

Were the defendant’s due process rights violated when he was required under state law to bear the burden of persuasion for his affirmative defense to the crime of murder?

Answer

“No. Judgment Affirmed.
In New York, the two elements to the crime of second-degree murder are: (1) intent to cause the death of another person

  • and (2) causing the death of such person or of a third person. Malice aforethought is not an element of the crime.”

    Conclusion

    New York affirmative defense laws did not violate the due process clause of the Fourteenth Amendment , since the affirmative defense in question constituted a separate issue on which the defendant was required to carry the burden of persuasion, and did not serve to negative any facts of the crime which the state had the burden of proving beyond a reasonable doubt in order to convict. The due process clause does not put a state to the choice of either abandoning affirmative defenses or undertaking to disprove their existence in order to convict for a crime which otherwise was within its constitutional powers to sanction by substantial punishment.

    • Case Brief: 1977
    • Appellant: Patterson
    • Appellee: New York
    • Decided by: Burger Court

    Citation: 432 US 197 (1977)
    Argued: Mar 1, 1977
    Decided: Jun 17, 1977