Rule
The state must prove every part of a crime beyond a reasonable doubt. A person accused of a crime may have to prove an affirmative defense, which is a reason that explains or excuses their actions.
Facts
Gordon Patterson, Jr. was charged with second-degree murder for shooting his wife's boyfriend. He claimed he acted under extreme emotional disturbance, a defense recognized by the state. The jury was told that Patterson had to prove this defense. If he did, his charge could be reduced to manslaughter. Despite his argument, the court said Patterson had to prove his defense, not the state.
Issue
The question is whether the state has to prove every part of a crime beyond a reasonable doubt and whether a person accused of a crime may have to prove an affirmative defense.
Application and Conclusion
The court said yes to both questions. It referred to a previous case where a defendant had to prove insanity. Many places started making defendants prove their defenses after this. In this case, New York would let Patterson use his defense to reduce his charge, but only if he could prove it. This didn't take away his rights. The state still had to prove he committed second-degree murder beyond a reasonable doubt. The court also said there are limits to how much a state can make a defendant prove.