Supreme Court of the United States · 1977 · Criminal Law
432 U.S. 197 (1977)
Updated
Criminal Lawburden of proofaffirmative defensesDue Process ClauseFourteenth Amendmentreasonable doubtaffirmative defenseextreme emotional disturbance
Facts
Patterson, estranged from his wife, borrowed a rifle, went to his father-in-law's house, saw his wife through a window in a state of semiundress with John Northrup, entered the house, and shot Northrup twice in the head. He was charged with second-degree murder, which under New York law required intent to cause death and causing death; malice aforethought was not an element. At trial, the jury was instructed that the State had to prove intent and causation beyond a reasonable doubt, but that Patterson had to prove the affirmative defense of extreme emotional disturbance by a preponderance of the evidence. The jury found him guilty of murder rather than manslaughter.
Issue
Whether the Fourteenth Amendment's Due Process Clause permits New York to place on a murder defendant the burden of proving the affirmative defense of extreme emotional disturbance by a preponderance of the evidence. More specifically, the question was whether that allocation unconstitutionally relieves the State of proving facts necessary to constitute murder beyond a reasonable doubt.
Rule
A State satisfies due process when it proves beyond a reasonable doubt all elements included in the definition of the charged offense. The State may place on the defendant the burden of proving an affirmative defense by a preponderance of the evidence when that defense does not negate any fact the State must prove to establish the crime, but instead constitutes a separate mitigating or exculpatory issue.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Ohio, a statute defines murder as intentionally causing another person's death. A separate provision allows a defendant to reduce the offense to manslaughter by proving, by a preponderance of the evidence, that he acted under an extreme emotional disturbance with a reasonable explanation. At trial in Cleveland, the judge repeatedly instructed the jury that the prosecution had to prove intent and causation beyond a reasonable doubt.
If the defendant argues that the burden on the mitigating defense violates due process, how should a court rule?
Explanation. Due process requires the prosecution to prove beyond a reasonable doubt every fact necessary to constitute the offense charged. But the State may place on the defendant the burden of proving an affirmative defense by a preponderance when that defense does not negative any element the State must prove. Here, the elements are intent, death, and causation; extreme emotional disturbance is a separate mitigating issue that reduces murder to manslaughter, so allocating its burden to the defendant is permissible. (Derived from Patterson v. New York (1977).)