Commonwealth v. York
| Commonwealth v. York | |
|---|---|
| Court | Supreme Judicial Court of Massachusetts |
| Full case name | Commonwealth v. Peter York |
| Decided | March 1, 1845 |
| Citation(s) | 50 Mass. 93 9 Metcalf 93 43 Am. Dec. 373 |
| Case opinions | |
| Decision by | Lemuel Shaw |
| Dissent | Samuel Wilde |
Commonwealth v. York, 50 Mass. (9 Metcalf) 93 (1845), is a precedent setting American criminal case in which it was determined that although the prosecution must establish all of the elements of a crime beyond a reasonable doubt, the defendant must prove the defense of provocation, which is about the defendant's mental state.[1]: 17 This was consistent with Blackstone's Commentaries that the prosecution must prove the defendant committed a criminal act, and the defendant must then prove "circumstances of justification, excuse and alleviation".[1]: 17 [2] In federal courts, but not state all courts, this changed with Davis v. United States (1895), which set precedent that there is a presumption of innocence as to having a mental state of being "legally capable of committing crime".[1]: 17
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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