People v. Casassa
49 N.Y.2d 668, 404 N.E.2d 1310 (1980)

  • Casassa was dating a girl named Victoria. After dating for a while, she broke it off. Casassa began stalking her. When she rejected his advances, he killed her.
  • Casassa was arrested and charged with murder.
    • Casassa argued that Victoria’s rejection devastated him and he was under extreme emotional disturbance at the time of the killing.
      • Under New York law, extreme emotional disturbance is an affirmative defense to second-degree murder where the defendant acted under the influence of extreme emotional disturbance for which there was a reasonable explanation or excuse.
        • Also see Model Penal Code §210.6(4)(b).
  • The Trial Court found Casassa guilty of second-degree murder. He appealed.
    • The Trial Court found that a reasonable person would not have been so disturbed by getting dumped. Therefore extreme emotional disturbance defense failed.
    • Casassa argued that the test should be subjectively applied to the emotional state of the defendant.
  • The New York Supreme Court upheld the conviction.
    • The New York Supreme Court found that extreme emotional disturbance requires two elements:
      • The particular defendant must have acted under the influence of extreme emotional disturbance.
        • That’s a subjective standard.
      • There must have been a reasonable explanation or excuse for the emotional disturbance. The reasonableness 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.
        • That’s an objective standard.
    • In this case, the Court agreed that Casassa was acting under an extreme emotional disturbance. However, that disturbance was not a reasonable one, and his actions were not what a reasonable person would do. Therefore the defense fails.