People v. Casassa

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Facts: D met and started casually dating the victim about seven months before the murder. After about four months, she told the D that she was not "falling in love" with him, which devastated the D. He broke into her apartment several times while she was out; one time he did so and disrobed and laid in her bed with a knife. On the final visit to the victim's apartment, D's offerings of several bottles of wine and liquor were rejected. He pulled out a steak knife and stabbed her several times in the throat, then dragged her into the bathtub to down her to make sure that she was dead.

Procedural History: Trial ct. found D guilty of murder in the second degree. D appealed because he was not afforded the benefit of the affirmative defense of "extreme emotional disturbance."

Issue: Was the D entitled to an affirmative defense of "extreme emotional disturbance"?

Arguments: The D was "extremely emotionally disturbed" - this was his affirmative defense. The reasonableness of his emotional disturbance" should be determined solely from his point of view.

Holding: No, the emotional disturbance was not reasonable. Trial ct. properly applied the statute.

Reasons: The emotional disturbance that the D was experiencing was unreasonable to others who looked at the situation from his point of view.

Judgment: Affirmed.

Comments: MPC gives two principle components to the "extreme emotional disturbance" affirmative defense: (1) the particular defendant must have acted under the influence of extreme emotional disturbance, and (2) there must have been a reasonable explanation or excuse for such extreme emotional disturbance, the reasonableness (of the extreme emotional disturbance) to be determined from the viewpoint of a person in the defendant's situation under the circumstances as the defendant believed them to be.