Werner v. Nassau County, 37 N.Y.2d 97 (1975)
Expert testimony is admissible to clarify proper police practices in emergency situations, even if no specific departmental rules or formal guidelines exist, and despite the jury’s general understanding of driving standards.
Summary
In a negligence case arising from a car accident during a high-speed police chase, the plaintiffs sued Nassau County, alleging the police created a roadblock. The trial court allowed the plaintiff’s expert to testify about proper police procedures, opining that the officer’s actions were improper. The Court of Appeals held that the expert testimony was admissible because it concerned specialized knowledge beyond the ken of the average juror regarding appropriate police conduct during emergencies. This decision highlights when expert testimony is helpful to the jury even when they possess general knowledge of the subject matter.
Facts
During a high-speed chase of a stolen vehicle, a Nassau County police officer positioned his vehicle on a four-lane road near an intersection. The plaintiffs, passengers in a car stopped at a red light, alleged that the police vehicle created a roadblock. They contended this caused the fleeing driver to skid and crash into their car, resulting in severe injuries. The defendant claimed the officer pulled over to the side of the road.
Procedural History
The plaintiffs sued Nassau County, claiming negligence. At trial, the plaintiffs presented an expert witness on emergency traffic procedures. The trial court admitted the expert testimony over the defendant’s objection. The jury returned a verdict in favor of the plaintiffs. The Appellate Division affirmed. The Court of Appeals granted leave to appeal and certified the question of whether the order of the Appellate Division was properly made.
Issue(s)
Whether the trial court erred in admitting expert testimony regarding proper police procedures during a high-speed chase.
Holding
Yes, the order of the Appellate Division should be affirmed because the expert testimony assisted the jury in understanding the proper standard of care for a police vehicle in an emergency situation, a matter beyond the ordinary knowledge of the average juror.
Court’s Reasoning
The Court of Appeals reasoned that expert testimony is admissible when it involves professional or scientific knowledge or skill not within the range of ordinary training or intelligence. While jurors possess a general understanding of the rules of the road, they lack specific knowledge of accepted police emergency practices. The Court noted that police officers have a special responsibility to apprehend violators while preventing them from endangering others. The Court emphasized that due to the unique experiences and responsibilities of police officers, special rules and accepted police emergency practices have developed creating a special standard of care for police drivers.
The court stated, “Since the police are confronted with a special responsibility not only for apprehending violators but also for preventing them from endangering others while at the same time operating their emergency vehicles in a manner that is neither careless, reckless nor wanton, however compelling the emergency special rules of accepted police emergency practices have naturally developed from this particular professional experience. That code, although often merely internal or even tacit, nevertheless creates a special standard of care for this particular class of drivers.”
The Court also emphasized that the defendant had the opportunity to cross-examine the expert or present their own expert testimony, but they chose not to. Therefore, the defendant could not claim prejudice as a result of the expert testimony.