Patterson v. New York

Patterson v. New York
Supreme Court of the United States
Argued March 1, 1977
Decided June 17, 1977
Full case namePatterson v. New York
Citations432 U.S. 197 (more)
97 S. Ct. 2319, 53 L. Ed. 2d 281, 1977 U.S. LEXIS 120
Holding
Shifting the burden of proof for a mitigating circumstance affirmative defense to the defendant does not violate the Due Process Clause of the U.S. Constitution.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Potter Stewart
Byron White · Thurgood Marshall
Harry Blackmun · Lewis F. Powell Jr.
William Rehnquist · John P. Stevens
Case opinions
MajorityWhite, joined by Burger, Stewart, Blackmun, Stevens
DissentPowell, joined by Brennan, Marshall
Rehnquist took no part in the consideration or decision of the case.
Laws applied
U.S. Const. Amend. XIV

Patterson v. New York, 432 U.S. 197 (1977), was a legal case heard by the Supreme Court of the United States that stated that the Due Process Clause Fourteenth Amendment did not prevent the burdening of a defendant to prove the affirmative defense of extreme emotional disturbance as defined by law in the state of New York.

The court found that the State of New York had reclassified provocation ("extreme emotional disturbance") as an excuse (an affirmative defense requiring proof by preponderance of the evidence), rather than mens rea, which the prosecution had to prove beyond a reasonable doubt, as was the situation in Mullaney v. Wilbur (1975).[1]: 18 

  1. ^ Criminal Law - Cases and Materials, 7th ed. 2012, Wolters Kluwer Law & Business; John Kaplan, Robert Weisberg, Guyora Binder, ISBN 978-1-4548-0698-1, [1]