New York Law Review

Tag: false confessions

  • People v. Tankleff, 49 A.D.3d 160 (2d Dep’t 2007): Admissibility of Expert Testimony on False Confessions

    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.”

  • People v. Bedessie, 19 N.Y.3d 147 (2012): Admissibility of Expert Testimony on False Confessions

    People v. Bedessie, 19 N.Y.3d 147 (2012)

    Expert testimony on the phenomenon of false confessions is admissible in a proper case, but the expert’s testimony must be relevant to the specific defendant and interrogation at issue.

    Summary

    Khemwattie Bedessie was convicted of sexually abusing a four-year-old boy. Before trial, she sought to introduce expert testimony on false confessions, arguing that her confession was coerced. The trial court denied this request, finding the testimony irrelevant and potentially usurping the jury’s role. The Court of Appeals affirmed, holding that while expert testimony on false confessions can be admissible, the proposed expert’s testimony was not relevant to Bedessie’s specific circumstances, as it focused on factors not present in her case and made speculative arguments. The court emphasized the importance of relevance and connection to the specific facts when admitting such expert testimony.

    Facts

    Khemwattie Bedessie, a teacher’s assistant, was accused of sexually abusing a four-year-old boy. The boy disclosed the abuse to his mother, who reported it to the authorities. Detective Bourbon interviewed Bedessie after advising her of her Miranda rights. Bedessie initially denied the allegations but then confessed to three incidents of sexual abuse. She later gave a videotaped confession detailing the events. Bedessie recanted her confession at trial, claiming Detective Bourbon coerced her into confessing by threatening her with jail and promising to let her go home to her sick mother if she confessed.

    Procedural History

    Bedessie was indicted on multiple counts, including rape and sexual abuse. She moved to suppress her confession as involuntary, which the trial court denied after a Huntley hearing. Before trial, Bedessie sought to introduce expert testimony on false confessions, which the trial court denied. The jury convicted Bedessie on all counts. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal.

    Issue(s)

    Whether the trial court erred in denying Bedessie’s request to introduce expert testimony on the phenomenon of false confessions.

    Holding

    No, because the proposed expert testimony was not relevant to the specific facts of Bedessie’s case and the circumstances of her interrogation.

    Court’s Reasoning

    The Court of Appeals acknowledged the growing recognition of the phenomenon of false confessions. Citing People v. Lee, the Court reiterated that the admissibility of expert testimony lies within the trial court’s discretion, guided by whether it would aid the jury. While expert testimony can “invade the jury’s province” to some degree, this alone is not grounds for exclusion. The Court found that the trial court did not abuse its discretion in denying Bedessie’s request. The expert’s report contained extraneous information, speculation, and conclusions unsupported by the facts. For instance, the expert discussed day-care sexual abuse cases and the suggestibility of young children, which was irrelevant to Bedessie’s claim that she was coerced into confessing. The court noted that “[w]hile electronic recording of interrogations should facilitate the discovery of false confessions and is becoming standard police practice, the neglect to record is not a factor or circumstance that might induce a false confession.” Furthermore, the expert did not proffer testimony that Bedessie exhibited personality traits linked to false confessions. The expert also made speculative claims about interrogation techniques without linking them to established research or Bedessie’s specific allegations. Ultimately, the Court concluded that the expert’s proffer was not relevant to Bedessie and her interrogation, making the testimony inadmissible. The Court emphasized that “While the expert may not testify as to whether a particular defendant’s confession was or was not reliable, the expert’s proffer must be relevant to the defendant and interrogation before the court.”