People v. Stone, 35 N.Y.2d 69 (1974)
Expert psychiatric testimony is admissible even if based in part on extrajudicial statements, provided the expert’s opinion is substantially based on their own examination of the defendant and facts already in evidence, and the extrajudicial statements serve primarily to confirm that opinion.
Summary
Gary Lee Stone was convicted of murdering his wife, with his sole defense being insanity. The appeal challenged the admissibility of a court-appointed psychiatrist’s (Dr. Jaenike) expert opinion, arguing it was improperly based on interviews with individuals who did not testify, violating the rule in People v. Keough. The Court of Appeals affirmed the conviction, holding that the trial court properly admitted the testimony because Dr. Jaenike’s opinion was substantially based on his own examinations of Stone and the facts in evidence, and the additional interviews merely confirmed his opinion. The court reasoned that a rigid application of Keough would discourage thorough psychiatric evaluations.
Facts
Stone was charged with the murder of his wife. His defense was insanity. Dr. Jaenike, a court-appointed psychiatrist, interviewed Stone six times, but Stone refused to discuss the circumstances of his wife’s death. After the last interview, Dr. Jaenike interviewed 12 other people, including friends, police officers, and doctors, four of whom did not testify at trial. At trial, Dr. Jaenike testified that based on his interviews with Stone and the other individuals, Stone possessed the substantial capacity to appreciate the wrongfulness of his conduct.
Procedural History
Stone was convicted of murder. He appealed, arguing that the trial court erred in admitting Dr. Jaenike’s testimony. The Court of Appeals affirmed the conviction.
Issue(s)
Whether an expert psychiatric opinion is admissible when it is based, in part, upon extrajudicial statements of people the psychiatrist spoke with after interviewing the defendant, where those people do not testify at trial.
Holding
No, because the psychiatrist’s opinion was substantially based on his own examination of the defendant and the facts in evidence, and the extrajudicial statements served primarily to confirm his opinion.
Court’s Reasoning
The court acknowledged the rule in People v. Keough, which generally limits expert opinions to those based solely on observation and examination of the defendant. However, the court noted that the purpose of the Keough rule is to aid the jury by ensuring that the facts upon which an expert opinion is based are before it. The court reasoned that a rigid application of the Keough rule would discourage psychiatrists from exploring relevant background information necessary for a sound medical opinion. The court found that Dr. Jaenike repeatedly stated that the additional interviews were conducted to “crystalize”, “substantiate”, “finalize” and “confirm” the view he had of Stone’s state of mind as a result of his interviews with Stone. The court emphasized that it had reasonably assured itself of a legally competent basis for Dr. Jaenike’s opinion in his interviews with Stone and the medical records in evidence. Furthermore, the court pointed to CPL 60.55, which modifies the strictness of the Keough rule and allows for the admission of psychiatric testimony where the opinion is substantially, though not exclusively, based upon observation and examination of the defendant and facts in evidence. The court concluded that the existence of further support for the opinion in medically sound but legally hearsay evidence affects the weight of the evidence, not its admissibility. The court also noted that the doctor was thoroughly cross-examined, and the jury was free to take the opinion for what they thought it was worth.