Patterson v. New York Case Brief Summary | Law Case Explained

Patterson v. New York | 432 U.S. 197 (1977)

As television crime shows have taught us, not all homicides are the same. Some people kill under the influence of extreme emotions, while others act in a premediated manner. Most states recognize this difference by reducing murder committed under an extreme emotional disturbance to the lesser offense of manslaughter. In Patterson versus New York, the United States Supreme Court looked at who bears the burden of proof in cases where a murder defendant claims to have suffered from an extreme emotional disturbance.

Gordon Patterson and his wife, Roberta, separated after a short and rocky marriage. Patterson repeatedly tried to reconcile with Roberta but was unsuccessful. Roberta filed for divorce and rekindled her relationship with a former boyfriend, John Northrup. Feeling distressed, Patterson drove to the house where Roberta was staying and looked into a window. After seeing Roberta in a state of partial undress standing next to Northrup, Patterson entered the home and fatally shot Northrup.

Patterson was charged with second-degree murder. At Patterson’s jury trial, the defense offered testimony from a psychiatrist and lay witnesses that Patterson was suffering from an extreme emotional disturbance when he shot Northrup. In accordance with a New York statute, the trial court instructed the jury that it could find Patterson guilty of manslaughter if he proved by a preponderance of the evidence that he had acted under the influence of an extreme emotional disturbance when he shot Northrup. The jury concluded that Patterson failed to meet his burden. Instead, the jury convicted Patterson of second-degree murder, finding beyond a reasonable doubt that Patterson intentionally killed Northrup.

Patterson appealed to the Appellate Division of the New York Supreme Court, which affirmed his conviction. On further appeal, the New York Court of Appeals affirmed the Appellate Division.

Patterson appealed to the United States Supreme Court, challenging the constitutionality of the state statute.

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