89 N.Y.2d 111 (1996)
When a defendant asserts an insanity defense, CPL 60.55(1) permits psychiatric experts to explain their diagnosis, but it does not automatically obviate the need for a Frye hearing to determine the reliability of novel scientific evidence like a neonaticide “syndrome.”
Summary
Stephanie Wernick was convicted of criminally negligent homicide after killing her newborn infant. On appeal, Wernick argued the trial court erred by precluding expert testimony about a neonaticide “syndrome” without a Frye hearing, claiming CPL 60.55(1) guarantees the admissibility of any explanation clarifying a psychiatric expert’s opinion. The New York Court of Appeals affirmed, holding that while CPL 60.55(1) allows experts to explain their diagnoses, it doesn’t eliminate the need for a Frye hearing to assess the reliability of novel scientific evidence. The court found the defense was attempting to introduce a novel theory without establishing its general acceptance in the relevant scientific community.
Facts
Stephanie Wernick gave birth to a baby boy in a college dormitory bathroom and subsequently asphyxiated the infant. She then enlisted a friend to help dispose of the body. Wernick was charged with manslaughter. The defense planned to present expert testimony arguing that Wernick suffered from a brief reactive psychosis due to her denial of the pregnancy, aligning with a proposed neonaticide “syndrome.”
Procedural History
The People requested a Frye hearing to assess the reliability of the neonaticide syndrome testimony. The trial court denied the request initially, planning to rule on the admissibility of the expert testimony as the trial progressed. The trial court allowed testimony regarding defendant’s denial of pregnancy and brief reactive psychosis but precluded experts from detailing a specific psychiatric profile of women who kill their newborns. The Appellate Division affirmed Wernick’s conviction. A dissenting Justice at the Appellate Division granted permission to appeal, arguing for a new trial after a Frye hearing.
Issue(s)
Whether CPL 60.55(1) automatically allows psychiatric experts testifying on an insanity defense to present any explanation clarifying their opinion, thereby precluding the need for a Frye hearing to determine the reliability of the underlying scientific basis for that opinion, such as a novel “neonaticide syndrome”?
Holding
No, because CPL 60.55(1) does not eliminate the requirement that novel scientific evidence, even when offered to explain a psychiatric expert’s opinion, must be shown to be generally accepted in the relevant scientific community under the Frye standard before it can be admitted.
Court’s Reasoning
The Court of Appeals reasoned that regardless of how the defense characterized the evidence (as a “pattern,” “profile,” or “syndrome”), the defense was attempting to introduce a pattern of behavior not generally recognized in the medical community. The court emphasized the importance of the Frye standard, which requires that expert testimony be based on scientific principles or procedures that have gained general acceptance in the relevant field. The court noted that CPL 60.55(1) was enacted to modify the common-law Keough rule, which limited expert testimony to facts in evidence and personal observation, but it does not completely eliminate the need to assess the reliability of the evidence underlying the expert’s opinion. Citing People v. Stone, the court stated that CPL 60.55 represents a balance between medical soundness and legal admissibility. While experts are permitted to explain their diagnoses, the court must ensure a legally competent basis for the expert’s opinion. According to the court, the statute requires that a psychiatric expert “be permitted to make any explanation reasonably serving to clarify his [or her] diagnosis and opinion”. Allowing experts to present publications of nontestifying experts about a theoretical profile without a reliability foundation would be improper. The court found that the trial court properly precluded the ultimate expert testimony regarding the neonaticide syndrome because the defense had not established a sufficient foundation for its reliability. The court explicitly rejected the dissent’s reading of CPL 60.55(1) as creating a broad exception to standard evidentiary rules.