Law School Case Brief
People v. Patterson - 39 N.Y.2d 288, 383 N.Y.S.2d 573, 347 N.E.2d 898 (1976)
The Due Process Clause, U.S. Const. amend. XIV, requires that a conviction cannot be had unless the prosecution proves beyond a reasonable doubt every fact necessary to constitute the crime with which a defendant is charged. In New York, the prosecution, in order to obtain a conviction for murder, must prove beyond a reasonable doubt that the defendant, with intent to cause the death of another person, did cause the death of such person or of a third person. N.Y. Penal Law § 125.25(1). With respect to intent, the People must establish that the defendant's conscious objective was to cause the death of the other person. N.Y. Penal Law § 15.05(1). Intent may not be inferred from the simple fact of killing, but must be proved by other facts. That New York will permit the defendant to establish the existence of mitigating circumstances, collateral to the principal facts at issue, does not detract in the smallest degree from the rule that the prosecution must prove intent beyond a reasonable doubt.
Defendant was convicted of murder after he shot his estranged wife's boyfriend. At his trial he raised the affirmative defense that he was acting under the influence of extreme emotional disturbance at the time of the incident, which would reduce the offense from murder to manslaughter. The jury was instructed that the burden of persuasion was on defendant with respect to whether he had been acting under the influence of extreme emotional disturbance. The appellate court affirmed the judgment, and defendant appealed.
Does placing the burden on defendant to show extreme emotional disturbance violate his due process rights?
The court held that putting the burden on defendant did not violate due process since extreme emotional disturbance was merely a mitigating circumstance that did not alter the prosecution's burden to prove intent, which was not negated by such disturbance.
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