November 10, 2013

People v. Casassa | Case Brief - 49 N.Y.2d 668, 404 N.E.2d 1310 (1980) - New York Court of Appeals

FACTS: Defendant had occasionally dated the victim.  She eventually told him she was not "falling in love" with him and he was devastated.  He began eavesdropping on her and once broke into her apartment, disrobed, and lay in her bed.  On his final visit to her he brought several bottles of wine and when she rejected the offer he pulled out a knife and stabbed her in the throat, then dragged her body into the bathroom and submerged it in water to make sure she was dead.

HISTORY:
Trial court found the defendant guilty of murder in the 2nd degree.

ISSUE:
Did the trial court err in not granting him the benefit of the affirmative defense of extreme emotional disturbance?

HOLDING:
No

RATIONALE:
The defense of extreme emotional disturbance has two main principals:

1) The particular defendant must have acted under the influence of extreme emotional disturbance

2) There must have been a reasonable explanation or excuse for such extreme emotional disturbance the reasonableness of which is to be determined from the viewpoint of a person in the defendant's situation under the circumstances as the defendant believed them to be

Component #1 is subjective

Component #2 is more objective in requiring a reasonable explanation for the actor's disturbance.

Because the test contains both subjective and objective elements it does expand the doctrine for evaluating "heat of passion" crimes while maintaining a degree of objectivity.

DISPOSITION:
Affirmed.