People v. Abney

Summary

The New York Court of Appeals considers whether trial courts abused their discretion by excluding expert testimony concerning the reliability of eyewitness identifications in two consolidated criminal cases. The court holds that exclusion was an abuse of discretion in Abney, where the prosecution’s case depended almost entirely on a single eyewitness identification and the proposed testimony included scientifically supported, counterintuitive factors. The court holds that exclusion was within the trial court’s discretion in Allen because the eyewitness identifications were corroborated by other evidence.

Holdings

1. The trial court abused its discretion by excluding Dr. Fulero's testimony concerning witness confidence and by failing to conduct a Frye hearing concerning the proposed testimony on event stress, exposure time, event violence and weapon focus, and cross-racial identification.
2. The trial court did not abuse its discretion in excluding the proposed expert testimony because Allen's case did not depend exclusively on a single eyewitness identification and substantial corroborating evidence connected him to the crime.
3. The erroneous exclusion of the expert testimony in Abney was not harmless.

Questions Presented

1. Whether the trial court abused its discretion by excluding expert testimony on eyewitness-identification reliability in Abney.
2. Whether the trial court abused its discretion by excluding similar expert testimony in Allen.
3. Whether the error in excluding the proposed expert testimony in Abney was harmless.

Disposition

other