In the case of Patterson v. New York, the U.S. Supreme Court upheld a New York law that placed the burden on defendants to prove "extreme emotional disturbance" in order to reduce a murder charge to manslaughter. The defendant, Patterson, had shot and killed his estranged wife's lover and was charged with second-degree murder. He claimed extreme emotional disturbance as an affirmative defense but failed to convince the jury beyond reasonable doubt about his mental state at the time of crime. The court ruled 5-4 that this did not violate due process rights under Fourteenth Amendment because it didn't shift responsibility for proving guilt away from prosecution; rather it allowed defendants opportunity for lesser punishment if they could demonstrate mitigating circumstances like extreme emotional distress. This ruling clarified states' ability to define their own criminal laws and defenses within constitutional boundaries.

In the dissenting opinion for Patterson v. New York, Justice Thurgood Marshall argued that the majority's decision violated due process by shifting the burden of proof to defendants in criminal cases. He contended that it is fundamentally unfair and contrary to established principles of justice for a defendant to be required to prove his or her innocence, rather than requiring the prosecution to establish guilt beyond reasonable doubt. This shift in burden could potentially lead innocent individuals being convicted if they are unable or fail to provide sufficient evidence supporting their defense. Furthermore, he expressed concern about potential inconsistencies across states regarding what defenses require proof from defendants and which do not - an issue left unresolved by this ruling.