In "Patterson v. New York", , however, the Court had held that New York's definition of homicide, which had no malice element, did not improperly force the defendant to disprove that he had acted with malice. New York was free to define homicide without reference to a malice element without violating the traditional rule that the burden of proof in criminal cases rests on the state. And in "McMillan v. Pennsylvania", , the Court held that a mandatory minimum five-year sentence for possessing a firearm was not subject to the jury-trial and proof-beyond-a-reasonable-doubt requirement, because it did not increase the maximum punishment to which the defendant was exposed.