People v. Jeter, 73 N.Y.2d 893 (1989)
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Expert testimony based on a novel scientific technique, such as voice spectrography, is inadmissible in New York unless it is shown to have gained general acceptance in the scientific community as reliable; such a determination cannot be made solely based on conflicting judicial opinions and legal literature without a preliminary inquiry into reliability.
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Summary
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Defendant was convicted of murder and weapon possession for fatally shooting a transit officer. A key piece of evidence was tape-recorded statements where Defendant admitted to the crime but later claimed were not his voice. The prosecution introduced voice spectrography evidence to identify the voice as belonging to the Defendant. The Court of Appeals held that admitting the spectrography evidence without a preliminary hearing on its reliability was erroneous because the technique’s acceptance in the scientific community was debated. However, the court deemed the error harmless due to other overwhelming evidence of guilt.
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Facts
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On September 21, 1984, the Defendant snatched a gold chain from a subway passenger. Transit Police Officers Lozada and Giambalvo pursued him. Officer Lozada caught the Defendant in a vacant lot but was overpowered and shot twice in the head with her own revolver. A witness, McGirt, saw the Defendant hovering over the officer and heard gunshots. The Defendant sold the chain, and both McGirt and the purchaser identified the Defendant in court.
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Procedural History
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The Defendant was convicted of second-degree murder and criminal possession of a weapon. He appealed, arguing the voice spectrography evidence was improperly admitted. The Appellate Division agreed it was error to admit the spectrographic evidence without a hearing but concluded the error was harmless. The Defendant then appealed to the New York Court of Appeals.
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Issue(s)
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Whether the trial court erred in admitting expert testimony regarding voice spectrography analysis without first holding a hearing to determine if the technique has gained general acceptance in the scientific community as reliable?
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Holding
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No, because the trial court lacked a proper basis to admit the voice spectrographic evidence without a preliminary inquiry into reliability. However, the error was harmless because other evidence overwhelmingly proved the defendant’s guilt.
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Court’s Reasoning
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The Court of Appeals addressed the admissibility of voice spectrography, a technique not previously ruled upon by a New York appellate court. The Court relied on the standard that novel scientific evidence must have “gained general acceptance in the scientific community” to be admissible. The Court found that existing case law and legal literature showed “marked conflict” regarding the reliability of voice spectrography, with jurisdictions and scholars split on its admissibility. The Court cited cases from other states, such as Windmere, Inc. v International Ins. Co., illustrating the ongoing debate. Because the trial court did not conduct a preliminary hearing to assess the reliability of the spectrography evidence, relying instead on the conflicting authorities, the Court of Appeals found this to be error. However, the Court applied the harmless error doctrine, finding that the spectrography evidence did not impact the admissibility of the defendant’s taped statements. Given these statements, the murder weapon found in the defendant’s room, and other testimony linking him to the crime, the Court concluded there was “overwhelming proof of guilt,” rendering the error harmless. The Court emphasized that the spectrographic evidence was only used to bolster the claim that it was the defendant’s voice on the tape, and the tape itself was highly incriminating. The court stated, “The voice spectrographie evidence did not affect the admissibility of the taped statements which, together with other testimony linking defendant to the shooting, the murder weapon found in defendant’s bedroom and defendant’s admitted commission of the chain snatching constitute overwhelming proof of guilt.”