People v. Casassa
Citation
49 N.Y.2d 668 (1980)
Facts
Victor Casassa became obsessively infatuated with a neighbor who rejected his advances; after she definitively rejected him, he broke into her apartment and killed her; he raised the affirmative defense of extreme emotional disturbance (EED) under New York Penal Law.
Issue
Whether the EED defense under New York law requires only a subjective showing that the defendant was genuinely disturbed, or also requires an objective showing that the disturbance had a reasonable explanation.
Holding
The Court of Appeals affirmed the murder conviction, holding that EED requires both a genuine subjective disturbance and an objectively reasonable explanation or excuse for it viewed from the defendant’s perspective.
Rule
The EED defense requires both a subjective, genuine emotional disturbance AND an objectively reasonable explanation for that disturbance from the defendant’s perspective; the disturbance must have a reasonable explanation or excuse, not merely be genuine — purely idiosyncratic reactions do not qualify.