People v. Miller, 69 N.Y.2d 913 (1987)

Evidence of post-accident design changes is inadmissible to prove negligent design but is admissible in a criminal case where the defendant claims a vehicle defect caused the accident, not their own negligence or intoxication.

Summary

Defendant was convicted of manslaughter and related charges after an automobile accident. The Appellate Division reversed, citing evidentiary errors. The Court of Appeals affirmed the reversal, holding that while evidence of post-accident design changes is typically inadmissible to prove negligent design, it is admissible here because the defendant was attempting to prove a vehicle defect caused the accident, not to demonstrate negligence on the part of the manufacturer. Furthermore, evidence regarding the Aleo-Sensor test was improperly admitted as reasonable cause for the breathalyzer test was not an element of the crime.

Facts

Defendant was involved in a fatal car accident and subsequently convicted of manslaughter, vehicular manslaughter, criminally negligent homicide, and driving under the influence. At trial, the prosecution introduced evidence of an Aleo-Sensor test to establish reasonable cause for a breathalyzer test. The defendant attempted to introduce evidence of subsequent design modifications to his vehicle, arguing that a vehicle defect, not his intoxication, caused the accident. The trial court excluded this evidence.

Procedural History

The trial court convicted the defendant. The Appellate Division reversed the conviction on the law and ordered a new trial, finding that the trial court erred in admitting evidence of the Aleo-Sensor test and excluding evidence of subsequent design modifications. The People appealed to the New York Court of Appeals.

Issue(s)

1. Whether the trial court erred in admitting evidence of the Aleo-Sensor test results to establish reasonable cause for the breathalyzer test.
2. Whether the trial court erred in excluding evidence of subsequent design modifications to the defendant’s vehicle offered to support the defense that a vehicle defect caused the accident.

Holding

1. Yes, because reasonable cause is not an element of the crimes charged, and the defendant did not dispute the breathalyzer test’s validity based on a lack of reasonable cause.
2. Yes, because the evidence was offered to prove a vehicle defect as the cause of the accident, not to prove negligent design by the manufacturer.

Court’s Reasoning

Regarding the Aleo-Sensor test, the Court of Appeals agreed with the Appellate Division that the evidence should have been excluded as irrelevant because reasonable cause to administer a breathalyzer is not an element of the charged crimes. The defendant never challenged the breathalyzer test’s validity on the grounds of lacking reasonable cause.

Regarding the post-accident design modifications, the Court distinguished this case from precedents like Cover v. Cohen and Caprara v. Chrysler Corp., which hold that evidence of post-accident design changes is inadmissible in strict liability or negligence cases to prove negligent design. The Court emphasized that the defendant wasn’t attempting to prove negligent design. Instead, he sought to prove a ‘defect’ in his vehicle caused the accident. The Court reasoned that “Here, however, the conduct of the manufacturer or seller in designing the vehicle was not at issue. Rather, consistent with his explanation at the scene of the accident, defendant sought only to prove the existence of a ‘defect’ in his automobile, as part of his defense.” Furthermore, the policy reasons for excluding evidence of post-accident repairs in civil cases—namely, not discouraging manufacturers from making safety improvements—did not apply in this criminal context.