Case brief summary
The government must prove every part of a crime beyond a reasonable doubt, but states can require defendants to prove special excuses that lower the charge by an easier standard.
Facts
Patterson killed a man he found with his estranged wife. New York charged him with murder, but let him try to prove he acted under extreme emotional disturbance to lower the charge to manslaughter.
Procedural history
A jury convicted Patterson of murder. His conviction was upheld on appeal, even after he argued a similar law in another state had been struck down by the Supreme Court.
Issue
Does it violate due process for a state to make a murder defendant prove, by a preponderance of the evidence, an affirmative defense of extreme emotional disturbance in order to reduce the charge to manslaughter?
Holding
No. Requiring the defendant to prove this affirmative defense does not violate due process, and Patterson's murder conviction is upheld.
Reasoning
New York only had to prove intent and causing death, which it did. The emotional disturbance defense was separate and didn't erase any fact the state needed to prove.
Opinions
Majority (White): A state may require a murder defendant to prove an affirmative defense like extreme emotional disturbance by a preponderance of the evidence without violating due process.
Dissent (Powell): The majority's test is too formalistic, focusing on statute wording rather than substance, and improperly weakens the constitutional requirement that the state prove every important fact affecting guilt or punishment beyond a reasonable doubt.