People v. Knight, 72 N.Y.2d 481 (1988)
Evidence obtained from moving radar devices is admissible in court without requiring expert testimony to explain the underlying scientific principles, provided the accuracy of the device is reasonably proven.
Summary
Knight was convicted of speeding based on evidence from a moving radar device. He challenged the admissibility of this evidence, arguing that expert testimony was necessary to establish the reliability of moving radar. The New York Court of Appeals affirmed the conviction, holding that moving radar evidence is admissible without expert testimony, similar to stationary radar. However, the prosecution bears a greater burden to demonstrate the accuracy of the moving radar by showing proper calibration, qualified operation, independent verification of the patrol vehicle’s speed, and minimal risk of interference or misidentification. The court found sufficient evidence to support the conviction, including the officer’s visual estimation of Knight’s speed.
Facts
Chief Hall, operating a moving radar device in his patrol car, visually estimated Knight’s speed at 70 mph in a 55 mph zone. Hall then activated the radar, which recorded Knight’s speed at 71 mph. The radar unit had been laboratory tested and Chief Hall tested the unit before and after his shift using internal and external calibration methods.
Procedural History
The Randolph Town Court convicted Knight of speeding. The County Court affirmed the conviction. Leave to appeal was granted by a Judge of the Court of Appeals.
Issue(s)
1. Whether moving radar evidence is admissible at trial without expert testimony explaining its underlying principles.
2. Whether the evidence presented was legally sufficient to sustain Knight’s speeding conviction.
Holding
1. Yes, because the underlying scientific principles of moving and stationary radar are the same, making expert testimony unnecessary, provided that reasonable proof of its accuracy is presented.
2. Yes, because the evidence presented, including the radar reading, the officer’s verification of the patrol car’s speed, and the officer’s independent visual estimation, sufficiently established Knight’s guilt.
Court’s Reasoning
The Court of Appeals relied on its prior decision in People v. Magri, which established that expert testimony is not required to explain the scientific principles of stationary radar. The court reasoned that both moving and stationary radar operate on the same Doppler Principle. While acknowledging a greater potential for error with moving radar, the court stated that this only increases the prosecution’s burden to demonstrate accuracy.
The court emphasized the following factors to establish the reliability of moving radar evidence: proper calibration of the radar unit, qualified operation by a trained officer, independent verification of the patrol vehicle’s speed (e.g., by comparing radar speed to speedometer speed), and use of the radar in an area with minimal risk of misidentification or distortion.
The court found that the evidence in this case was sufficient. The court noted that “evidence of speeding obtained by means of moving radar generally will be admissible and ‘may be sufficient in [itself] if there be reasonable proof of [its] accuracy’”. The Court noted, also, that Chief Hall independently verified his speed and road conditions were unlikely to cause distortion. Even without the radar evidence, Chief Hall’s visual estimation of Knight’s speed independently supported the conviction. The court stated, “even if the radar evidence standing alone were deemed insufficient to support the conviction, there is additional evidence here that sufficiently corroborates the accuracy of the radar reading so as to establish defendant’s guilt beyond a reasonable doubt.”