PATTERSON V. NEW YORK WAS AN OPPORTUNITY FOR THE SUPREME COURT TO RESOLVE THE UNCERTAINTY GENERATED BY THE MULLANEY DECISION'S EXTENSION OF WINSHIP'S REASONABLE DOUBT STANDARD TO MATTERS CORRESPONDING TO THE GUILT DETERMINATION IN CRIMINAL ACTIONS. RATHER THAN ENUNCIATE A CLEAR RULE FOR APPLYING THE REASONABLE DOUBT STANDARD, HOWEVER, THE COURT ATTEMPTED TO DISTINGUISH MULLANEY BY CONTRASTING MAINE'S USE OF A PRESUMPTION TO ALLOCATE A PERSUASION BURDEN TO THE DEFENDANT WITH NEW YORK'S ALLOCATION OF THE SAME BURDEN BY EMPLOYING AN AFFIRMATIVE DEFENSE. UNFORTUNATELY, ON THE BASIS OF THE FORM EMPLOYED BY THE STATUTORY SCHEME PROVIDES NO USEFUL GUIDANCE IN PROPERLY BALANCING THE FEDERAL INTEREST IN PROTECTING THE DEFENDANT'S DUE PROCESS RIGHTS WITH THE STATE'S INTEREST IN DEFINING AND CONTROLLING CRIMINAL BEHAVIOR. THUS, PATTERSON LEAVES THE TENSION BETWEEN THESE INTERESTS UNRESOLVED AND FORCES LOWER COURTS TO DETERMINE ON A CASE-BY-CASE BASIS THE WEIGHT TO BE ACCORDED EACH. THE DANGER INHERENT IN A CASE-BY-CASE ANALYSIS OF FEDERAL AND STATE INTERESTS LIES IN THE POSSIBILITY THAT AS LOWER COURTS INTERPRET PATTERSON'S MANDATE, THE CRIMINAL DEFENDANT'S FUNDAMENTAL RIGHT TO HAVE GUILT PROVED BEYOND A REASONABLE DOUBT MAY BE COMPROMISED. EXTENSIVE FOOTNOTES ARE PROVIDED. (AUTHOR ABSTRACT MODIFIED--RCB)