People v. Young, 7 N.Y.3d 40 (2006)
A trial court has discretion to admit or deny expert testimony on the reliability of eyewitness identification, but that discretion should lean towards admission when identification evidence is weak and uncorroborated.
Summary
This case addresses the admissibility of expert testimony on eyewitness identification. The defendant was convicted of robbery and burglary based on a witness’s identification, which was preceded by a suppressed lineup identification. The trial court denied the defendant’s request to present expert testimony on factors affecting eyewitness reliability. The New York Court of Appeals affirmed the conviction, holding that the trial court did not abuse its discretion. However, the dissent argued that the expert testimony should have been admitted given the weakness of the eyewitness identification and lack of corroborating evidence. This case highlights the complexities and judicial discretion involved in determining the reliability of eyewitness testimony.
Facts
William and Lisa Sykes were victims of a home invasion in March 1991. The perpetrator wore a scarf and blanket, obscuring his face but revealing his eyes, forehead, and part of his nose. Lisa Sykes described the assailant to police. She could not create a composite sketch or identify anyone in a photo array. She later identified the defendant, Young, in a lineup. Young’s initial conviction was reversed due to a lack of probable cause for his arrest, leading to suppression of the lineup identification.
Procedural History
1. Defendant was initially convicted in 1992.
2. The conviction was reversed by the Appellate Division in 1998 due to an unlawful arrest.
3. Prior to the second trial, the trial court held an independent source hearing to determine if Mrs. Sykes had a basis to identify Young independent of the tainted lineup.
4. Defendant was convicted again in January 2000.
5. The Appellate Division affirmed the second conviction.
6. The New York Court of Appeals affirmed, with a dissent.
Issue(s)
Whether the trial court abused its discretion by precluding expert testimony on the reliability of eyewitness identification, given that the primary identification evidence was potentially tainted and uncorroborated.
Holding
No, because the decision to admit expert testimony on eyewitness identification rests within the trial court’s discretion, and in this instance, the trial court’s decision was not an abuse of that discretion.
Court’s Reasoning
The Court of Appeals majority found that the trial court was within its discretion to exclude the expert testimony. However, the dissent argued that excluding the testimony was an error, especially given the circumstances of the identification. The dissent emphasized that Mrs. Sykes could not initially create a composite sketch or identify Young in a photo array, and her identification only occurred after the illegal lineup. The dissent cited People v. Lee, 96 N.Y.2d 157 (2001), noting that while trial courts have discretion, the trend favors admitting expert testimony on eyewitness identification when it would assist the jury. The dissent pointed out that, unlike People v. Lee, where the witness made multiple identifications, Mrs. Sykes’s identification was more tenuous. The dissent quoted People v. Mooney, 76 NY2d 827, 829 (1990), stating that “the emerging trend today is to find expert psychological testimony on eyewitness identification sufficiently reliable to be admitted, and the vast majority of academic commentators have urged its acceptance”. The dissent argued that when eyewitness identification is attenuated and uncorroborated, courts should be more inclined to allow expert testimony. The expert’s testimony was intended to show the weak correlation between witness confidence and accuracy, the difficulty of remembering a face when the mind cannot encode all the features at once, and the possibility of memory source confusion. Allowing it would have assisted the jury in assessing the reliability of Mrs. Sykes’ identification.