People v. Goldstein

Summary

The New York Court of Appeals reversed Andrew Goldstein's murder conviction and ordered a new trial. The court held that admitting a prosecution psychiatrist's testimony recounting testimonial statements from unavailable interviewees violated the defendant's constitutional right to confront witnesses under Crawford v. Washington. The court rejected the defendant's state hearsay challenge but concluded that the constitutional error was not harmless beyond a reasonable doubt.

Holdings

1. A qualified expert's testimony may establish that out-of-court material relied upon by a psychiatrist is of a kind accepted in the profession as reliable; the prosecution met that burden through Hegarty's testimony, so her expert opinion was admissible under People v. Stone and People v. Sugden.
2. The statements recounted by Hegarty were hearsay offered for their truth and were testimonial because they were obtained through prosecution trial-preparation interviews by an expert retained to testify for the People. Their admission violated Goldstein's federal constitutional right of confrontation.
3. The People failed to prove beyond a reasonable doubt that admission of the four testimonial statements was harmless; the statements provided significant support for the prosecution's theory of sanity and could reasonably have affected the verdict.
4. On the facts of the case, the trial court acted within its discretion in precluding the defense expert's extreme-emotional-disturbance testimony and in refusing to order a PET scan.

Questions Presented

1. Whether third-party statements recounted by the prosecution's psychiatrist were admissible under New York's rule permitting an expert psychiatrist to rely on out-of-court material accepted as reliable in the profession.
2. Whether admission of the third-party interviewees' statements violated Goldstein's federal and state constitutional rights to confront the witnesses against him.
3. Whether any confrontation violation was harmless beyond a reasonable doubt.
4. Whether the trial court abused its discretion by precluding defense expert testimony concerning extreme emotional disturbance or by refusing to order a PET scan.

Disposition

reversed_and_remanded