People v. Harris - 95 N.Y.2d 316, 717 N.Y.S.2d 82, 740 N.E.2d 227 (2000)

Rule:

The extreme emotional disturbance defense requires proof of both subjective and objective elements. The subjective element focuses on the defendant's state of mind at the time of the crime and requires sufficient evidence that the defendant's conduct was actually influenced by an extreme emotional disturbance. This element is generally associated with a loss of self-control. The objective element requires proof of a reasonable explanation or excuse for the emotional disturbance. Whether such a reasonable explanation or excuse exists must be determined by viewing the subjective mental condition of the defendant and the external circumstances as the defendant perceived them to be at the time, however inaccurate that perception may have been, and assessing from that standpoint whether the explanation or excuse for the emotional disturbance was reasonable.

Facts:

Defendant was convicted after a jury trial of murder in the second degree. The evidence established that defendant killed his long-time friend, Larry Amorose, with a machete. With the help of his girlfriend, defendant decapitated and dismembered Amorose's body, put the body parts in garbage bags and discarded the bags in the ocean off Coney Island. The trial court rejected defendant’s request for a charge on extreme emotional disturbance on the ground that the evidence was insufficient to justify submission of that affirmative defense to the jury. The Appellate Division affirmed the judgment of conviction. Defendant appealed, contending that the lower courts erred by rejecting his request for a charge to the jury of the affirmative defense of extreme emotional disturbance pursuant to N.Y. Penal Law § 125.25(1)(a). 

Issue:

Did the lower courts err in rejecting defendant’s request for a charge to the jury of the affirmative defense of extreme emotional disturbance pursuant to N.Y. Penal Law § 125.25(1)(a)? 

Answer:

Yes.

Conclusion:

Viewing the evidence in the light most favorable to the defendant, the court of appeals found the extreme emotional disturbance defense should have been charged to the jury. The court held that the jury could reasonably infer that he was provoked to rage over the emotionally-charged subject of his lover's past and potentially future infidelity with victim. A rational jury could conclude that defendant exhibited the severe loss of self-control normally associated with the subjective element of the extreme emotional disturbance defense and that defendant satisfied the objective element of the defense. The court concluded that defendant presented sufficient evidence with respect to both elements of the defense of extreme emotional disturbance so as to be entitled to the charge.