People v. Geoghegan, 51 N.Y.2d 42 (1980)
A statement against penal interest made by an accomplice is inadmissible if the circumstances surrounding the statement indicate a motive to falsify or shift blame, even if the statement aligns with other evidence.
Summary
The New York Court of Appeals affirmed the reversal of a murder and robbery conviction because the trial court improperly admitted an accomplice’s confession as a declaration against penal interest. The court held that the accomplice, Jones, had a motive to falsify his statement to minimize his own involvement and implicate others, especially since he believed the police already knew of his involvement. The Court of Appeals emphasized that the circumstances surrounding the statement must all but rule out any motive to falsify for it to be admissible, and that wasn’t the case here.
Facts
Geoghegan was convicted of murder and robbery related to the death of a wealthy man. The prosecution’s case relied heavily on the testimony of Gilligan, an accomplice who pleaded guilty to a lesser charge. Jones, another accomplice, initially denied involvement but later confessed after seeing Geoghegan and Gilligan in custody. Jones’s confession implicated Geoghegan, but Jones refused to testify at Geoghegan’s trial. Instead, detectives were permitted to recount Jones’s confession, omitting direct references to Geoghegan, although one reference slipped in during testimony.
Procedural History
The trial court convicted Geoghegan of second-degree murder and robbery. The Appellate Division reversed the conviction, finding that Jones’s statement was improperly admitted. The People appealed to the New York Court of Appeals.
Issue(s)
Whether a statement made by an accomplice, characterized as a declaration against penal interest, was properly admitted against the defendant when the circumstances suggest a motive to falsify.
Holding
No, because under the circumstances, the accomplice had a motive to falsify his statement and minimize his own involvement while implicating others.
Court’s Reasoning
The Court of Appeals applied the standard from People v. Maerling, which requires that a statement against penal interest be admissible only if the interest compromised is such as to