People v. Angelo, 88 N.Y.2d 217 (1996)
Polygraph test results are inadmissible as evidence in New York criminal trials because they are not generally accepted within the scientific community as reliable.
Summary
Angelo, a nurse, was convicted of murder and assault for injecting patients with a neuromuscular blocking agent. At trial, he argued a mental illness prevented him from understanding the risk of his actions. He sought to introduce polygraph results, arguing they supported his expert’s diagnosis. The trial court excluded the polygraph evidence, citing its unreliability. The Court of Appeals affirmed, holding that polygraph results are inadmissible unless generally accepted as reliable in the scientific community, which Angelo failed to demonstrate. This case reinforces the application of the *Frye* standard in New York, requiring scientific reliability for novel scientific evidence.
Facts
Angelo, a nurse, injected seven patients with a neuromuscular blocking agent, leading to six deaths. He claimed a dissociative disorder prevented him from understanding the risk his actions posed to the patients. Angelo sought to prove that he had feelings of inadequacy, and injected patients so he could then participate in their resuscitation, unaware that his injections caused their distress.
Procedural History
Angelo was convicted of murder, manslaughter, criminally negligent homicide, and assault. The Appellate Division affirmed. The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether the trial court erred in prohibiting Angelo’s expert from testifying that his conclusions were based, in part, on the results of Angelo’s polygraph examination.
Holding
No, because polygraph test results are not generally accepted by the scientific community as reliable and therefore are inadmissible as evidence.
Court’s Reasoning
The Court of Appeals upheld the trial court’s decision to exclude the polygraph evidence. The Court reasoned that while experts can rely on out-of-court evidence, that evidence must be “of a kind accepted in the profession as reliable in forming a professional opinion” or “comes from a witness subject to full cross-examination on the trial” (citing People v. Sugden, 35 N.Y.2d 453, 460-461). This incorporates the *Frye* standard, requiring general acceptance of the scientific procedures and methodology. Because Angelo failed to demonstrate that polygraph test results meet this standard, the evidence was properly excluded.
Specifically, the Court stated, “Because defendant did not demonstrate that polygraph test results are generally accepted by the scientific community as reliable, County Court did not err in excluding defendant’s polygraph results.”
The court also noted that Angelo did not properly preserve his argument that a *Frye* hearing should have been held, as he did not definitively request such a hearing or argue that the scientific consensus had changed since previous rulings deeming polygraph evidence inadmissible.
Finally, the Court rejected Angelo’s argument that the validity of the test results was not at issue, clarifying that because the polygraph was offered to prove the honesty of Angelo’s belief, its probative value depended on the reliability of the test results.