Patterson v. New York

In Patterson v. New York, 432 U.S. 197, 97 S. Ct. 2319, 53 L. Ed. 2d 281 (1977) Patterson picked up on Mullaney's discussion of a legislature's ability to define the elements of a crime. Since these limits are of crucial importance to whether prior convictions are elements, or sentencing factors, under the POAA, this portion of Patterson is relevant here. According to Patterson, the reasonable-doubt standard is dependent on how the State defines the offense in question, and the legislature's definition of the elements of an offense is usually dispositive. Patterson, 432 U.S. at 210, 211 n.12. Nevertheless, there are constitutional limits beyond which legislators may not go in determining what should be an element subject to proof beyond a reasonable doubt and what should be a mere sentencing factor. Patterson, 432 U.S. at 210. That is where Patterson left off, apparently leaving it to later opinions to iron out where these limits should be drawn.