People v. Tankleff, 49 A.D.3d 160 (2d Dep’t 2007)

Expert testimony on the reliability of confessions, including factors that can lead to false confessions, is admissible when it is relevant to the specific circumstances of the case and the expert is qualified.

Summary

This case addresses the admissibility of expert testimony regarding false confessions. Martin Tankleff was convicted of murdering his parents, largely based on his confession to police. On appeal, Tankleff argued the trial court erred in precluding expert testimony on factors influencing the reliability of confessions. The Appellate Division held that the trial court erred in precluding the expert testimony because Tankleff’s confession had inconsistencies that made the testimony relevant. This ruling highlights the importance of allowing expert testimony to assist juries in evaluating the validity of confessions, particularly when there are indicia of unreliability or coercion.

Facts

Martin Tankleff was convicted of the murders of his parents, based primarily on a confession he made to detectives during interrogation. Tankleff initially denied any involvement but, after being told he failed a polygraph test (which was inadmissible), he confessed to the crime. He later recanted the confession, claiming it was coerced and false. Prior to trial, Tankleff sought to introduce expert testimony on factors that can lead to false confessions, aiming to cast doubt on the reliability of his statement to the police. The trial court denied this request, deeming the expert testimony inadmissible.

Procedural History

Tankleff was convicted in the trial court. He appealed to the Appellate Division, Second Department, arguing that the trial court erred in precluding expert testimony on false confessions. The Appellate Division reversed the conviction and ordered a new trial, finding that the exclusion of the expert testimony was an abuse of discretion.

Issue(s)

Whether the trial court erred in precluding expert testimony regarding factors that could have influenced the reliability of the defendant’s confession.

Holding

Yes, because the expert testimony on factors associated with false confessions was relevant to the particular circumstances of the defendant’s confession and would have aided the jury in evaluating the confession’s reliability.

Court’s Reasoning

The Appellate Division emphasized that expert testimony is admissible if it would help to clarify issues calling for professional or technical knowledge, possessed by the expert and beyond the ken of the typical juror. The court noted that while jurors may generally understand that a person can falsely confess, they may lack an understanding of the specific psychological factors and interrogation techniques that can contribute to false confessions. Citing inconsistencies within Tankleff’s confession, along with the interrogation tactics used by the detectives, the court found that expert testimony was especially relevant in this case. The court distinguished cases where expert testimony on eyewitness identification was deemed inadmissible because unlike eyewitness testimony, the dynamics of police interrogations and their potential to induce false confessions are not within the common knowledge of jurors. The court also noted that the exclusion of the expert testimony prejudiced Tankleff, as his confession was a critical piece of evidence presented by the prosecution. The court referenced People v. Lee, 96 N.Y.2d 157 (2001), as a guiding precedent for determining the admissibility of expert testimony in such cases, reiterating that the testimony must be directly relevant to the circumstances of the confession at issue. The court stated: “Under the circumstances presented here, expert testimony regarding false confessions should have been admitted to aid the jury in reaching a determination as to the reliability of the defendant’s confession.”