World Library  
Flag as Inappropriate
Email this Article

Patterson v. New York

Article Id: WHEBN0015170337
Reproduction Date:

Title: Patterson v. New York  
Author: World Heritage Encyclopedia
Language: English
Subject: Schlup v. Delo, Kyles v. Whitley, Dusky v. United States, Drope v. Missouri, Godinez v. Moran
Publisher: World Heritage Encyclopedia

Patterson v. New York

Patterson v. New York
Argued March 1, 1977
Decided June 17, 1977
Full case name Patterson v. New York
Citations 432 U.S. 197 (more)
Shifting the burden of proof to the Defendant of a mitigating circumstance affirmative defense does not violate the Due Process Clause of the U.S. Constitution.
Court membership
Case opinions
Majority White, joined by Burger, Stewart, Blackmun, Stevens
Dissent Powell, joined by Brennan, Marshall
Rehnquist took no part in the consideration or decision of the case.

Patterson v. New York, 432 U.S. 197 (1977), is a legal case heard by the United States Supreme Court regarding the constitutionality under the Fourteenth Amendment's Due Process Clause of burdening a defendant with proving the affirmative defense of extreme emotional disturbance as defined by New York law.


After a brief and unstable marriage, the appellant, Gordon Patterson, Jr., became estranged from his wife, Roberta. Roberta resumed an association with John Northrup, a neighbor to whom she had been engaged prior to her marriage to appellant. On December 27, 1970, Patterson borrowed a rifle from an acquaintance and went to the residence of his father-in-law. There, he observed his wife through a window in a state of semiundress in the presence of John Northrup. He entered the house and killed Northrup by shooting him twice in the head.

Patterson was charged with second-degree murder. In New York, there were two elements of this crime: (1) "intent to cause the death of another person"; and (2) "causing the death of such person or of a third person." – N.Y. Penal Law. Malice aforethought is not an element of the crime. The State of New York allowed a person accused of murder to raise an affirmative defense that he "acted under the influence of extreme emotional disturbance for which there was a reasonable explanation or excuse."

The New York law required that the defendant in this and any prosecution for second-degree murder prove by a preponderance of the evidence the affirmative defense of extreme emotional disturbance in order to reduce the crime to manslaughter.

A trial court jury found Patterson guilty for murder. On appeal, the New York Court of Appeals found the law (and verdict) not to violate Patterson's Constitutional rights as guaranteed under the Due Process Clause of the Fourteenth Amendment.

The case was appealed to the US Supreme Court. It was argued March 1, 1977 and decided June 17, 1977

Victor Rubino argued the cause for appellant. With him on the briefs was Betty Friedlander. John Finnerty argued the cause for appellee. With him on the brief was Alan Marrus.

The decision

Affirmed. The decision was delivered by Justice Byron White in which Justice Warren E. Burger, Justice Potter Stewart, Justice Harry Blackmun and Justice John Paul Stevens joined. Justice Lewis F. Powell, Justice William J. Brennan and Justice Thurgood Marshall dissented. Justice William Rehnquist took no part in the consideration or the decision of the case.

The Court decided that shifting the burden of proof to the Defendant of a mitigating circumstance affirmative defense does not violate the Due Process Clause of the U.S. Constitution.

See also

Further reading


  • Patterson v. New York on Justia
  • Oyez
  • Case Law
  • Overview by
This article was sourced from Creative Commons Attribution-ShareAlike License; additional terms may apply. World Heritage Encyclopedia content is assembled from numerous content providers, Open Access Publishing, and in compliance with The Fair Access to Science and Technology Research Act (FASTR), Wikimedia Foundation, Inc., Public Library of Science, The Encyclopedia of Life, Open Book Publishers (OBP), PubMed, U.S. National Library of Medicine, National Center for Biotechnology Information, U.S. National Library of Medicine, National Institutes of Health (NIH), U.S. Department of Health & Human Services, and, which sources content from all federal, state, local, tribal, and territorial government publication portals (.gov, .mil, .edu). Funding for and content contributors is made possible from the U.S. Congress, E-Government Act of 2002.
Crowd sourced content that is contributed to World Heritage Encyclopedia is peer reviewed and edited by our editorial staff to ensure quality scholarly research articles.
By using this site, you agree to the Terms of Use and Privacy Policy. World Heritage Encyclopedia™ is a registered trademark of the World Public Library Association, a non-profit organization.

Copyright © World Library Foundation. All rights reserved. eBooks from World Library are sponsored by the World Library Foundation,
a 501c(4) Member's Support Non-Profit Organization, and is NOT affiliated with any governmental agency or department.