People v. Leone, 25 N.Y.2d 511 (1969)

Polygraph test results are inadmissible as evidence in criminal trials in New York because their reliability and general scientific acceptance have not been sufficiently established.

Summary

The defendant was charged with murder and the prosecution sought to introduce polygraph test results as evidence of his guilt. The trial court suppressed the evidence, and the Appellate Division affirmed. The New York Court of Appeals affirmed, holding that polygraph tests lack the requisite scientific acceptance and reliability to be admissible in criminal trials. The court reviewed conflicting views on polygraph efficacy and emphasized the need for caution when admitting evidence that could heavily influence a jury. This case highlights the ongoing debate surrounding the use of scientific evidence in court and sets a high bar for admissibility.

Facts

The defendant was a suspect in a triple homicide. He was questioned by the State Police multiple times regarding his whereabouts on the night of the murders. After the police expressed disbelief in his alibi, the defendant consented to a polygraph examination. The examination was conducted by a Senior Investigator using a Stoelting polygraph machine, which measured respiration, blood pressure, heart rate, and skin resistance. The District Attorney intended to introduce the polygraph test findings at trial to prove the defendant’s guilt.

Procedural History

The Jefferson County Court granted the defendant’s motion to suppress the polygraph test results. The Appellate Division, Fourth Department, affirmed this decision without opinion. The People appealed to the New York Court of Appeals.

Issue(s)

Whether polygraph test results are admissible as evidence in a criminal trial to prove the guilt or innocence of the defendant.

Holding

No, because the reliability and general scientific acceptance of polygraph tests have not been sufficiently established to warrant their admissibility in criminal trials.

Court’s Reasoning

The Court of Appeals acknowledged the increasing use of polygraphs in industry but emphasized that prior precedent (People v. Forte) required sufficient establishment of reliability before evidentiary standing could be granted in criminal law. The Court discussed the conflicting views on polygraph efficacy, noting proponents’ claims of high accuracy and opponents’ contentions regarding the lack of scientific proof linking deception to measurable physiological reactions. The Court referenced a congressional subcommittee report skeptical of polygraph reliability. The court also noted arguments that even if the polygraph results were statistically relevant the lack of standardized training for the polygraph examiner would make the results unreliable. The Court found that the prosecution failed to demonstrate “a general scientific recognition that the [polygraph] possesses efficacy.” The court highlighted the potential for jurors to give undue weight to polygraph results. The court reasoned that admitting polygraph results prematurely, before general reliability is proven, risks making the test itself the focus of the trial, rather than the defendant’s guilt or credibility. Citing People v. Davis, the court emphasized the need for caution and clear recognition of reasonable accuracy and general scientific acceptance before admitting such evidence.