Commonwealth v. York, 50 Mass. (9 Metcalf) 93 (1845), is a precedent-setting American criminal case that established the principle that although the prosecution must prove all elements of a crime beyond a reasonable doubt, the defendant bears the burden of proving the defense of provocation, which pertains to the defendant's mental state.[1]: 17 This ruling was consistent with Blackstone's Commentaries, which held that prosecution must prove the defendant committed a criminal act, and the defendant must then prove "circumstances of justification, excuse and alleviation".[1]: 17 [2] However, in federal courts, but not state all courts, this precedent was later modified by Davis v. United States (1895), which established the presumption of innocence regarding a defendant's mental state of being "legally capable of committing crime".[1]: 17
| Commonwealth v. York | |
|---|---|
| Court | Supreme Judicial Court of Massachusetts |
| Full case name | Commonwealth v. Peter York |
| Decided | March 1, 1845 |
| Citations | 50 Mass. 93 9 Metcalf 93 43 Am. Dec. 373 |
| Case opinions | |
| Decision by | Lemuel Shaw |
| Dissent | Samuel Wilde |
References
edit- ^ a b c Criminal Law - Cases and Materials, 7th ed. 2012, Wolters Kluwer Law & Business; John Kaplan, Robert Weisberg, Guyora Binder, ISBN 978-1-4548-0698-1, [1]
- ^ 4 Blackstone's Commentaries 201 (1769)
External links
edit- Text of Commonwealth v. York, 50 Mass. (9 Metcalf) 93 (1845) is available from: Justia
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