People v. Aphaylath, 68 N.Y.2d 945 (1986)

Expert testimony on cultural context is admissible to support an extreme emotional disturbance defense, even if the expert has no personal knowledge of the defendant, as long as the testimony is relevant and probative to a fact in issue; the trial court has discretion to determine its relevance and probative value.

Summary

Aphaylath, a Laotian refugee, was convicted of intentionally murdering his wife. He claimed extreme emotional disturbance due to cultural differences and the stress of being a refugee. The trial court excluded expert testimony about the challenges faced by Laotian refugees assimilating into American culture because the experts lacked specific knowledge of the defendant. The New York Court of Appeals reversed, holding that expert testimony doesn’t require personal knowledge of the defendant if it’s relevant to a fact in issue. The court determined the exclusion of expert testimony was an error, warranting a new trial.

Facts

Defendant, a Laotian refugee who had been in the U.S. for two years, was charged with the intentional murder of his wife, whom he had married a month prior.
He argued that the stress of being a refugee and cultural differences contributed to an extreme emotional disturbance.
His defense was that his wife’s behavior—showing affection for a former boyfriend and receiving calls from another man—brought shame on him and his family according to Laotian culture, triggering his loss of control.

Procedural History

The defendant was indicted and tried in the Supreme Court, Monroe County.
He attempted to present an affirmative defense of extreme emotional disturbance.
The trial court excluded the testimony of two expert witnesses.
This decision was appealed, and the New York Court of Appeals reversed the order and remitted the case for a new trial.

Issue(s)

Whether the trial court erred in excluding expert testimony regarding the stress and disorientation experienced by Laotian refugees assimilating into American culture, offered to support the defendant’s affirmative defense of extreme emotional disturbance.

Holding

Yes, because the admissibility of expert testimony that is probative of a fact in issue does not depend on whether the witness has personal knowledge of a defendant or a defendant’s particular characteristics.

Court’s Reasoning

The Court of Appeals found that the trial court’s exclusion of expert testimony was based on an erroneous legal standard. The trial court reasoned that because the experts lacked specific knowledge of the defendant, their testimony was inadmissible. The Court of Appeals clarified that the admissibility of expert testimony doesn’t hinge on the expert’s personal knowledge of the defendant. The court cited Kulak v Nationwide Mut. Ins. Co., 40 NY2d 140, 146-147, emphasizing that expert testimony is admissible if it’s “probative of a fact in issue.” The court further explained that the trial judge has discretion to determine whether the testimony is sufficiently relevant to have probative value (De Long v County of Erie, 60 NY2d 296, 307).

The court noted that the defendant may have been deprived of the opportunity to present relevant information to the jury. The exclusion was deemed prejudicial because the expert testimony was directly relevant to the defendant’s affirmative defense of extreme emotional disturbance. The court stated, “Whether or not such testimony is sufficiently relevant to have probative value is a determination to be made by the Trial Judge in the exercise of her sound discretion.”

In essence, the Court of Appeals established that while trial courts have discretion in admitting expert testimony, they cannot categorically exclude such testimony solely because the expert lacks personal knowledge of the defendant. The focus should be on the relevance and probative value of the testimony to the facts at issue, particularly when it supports an affirmative defense like extreme emotional disturbance that is rooted in cultural context.