People v. Boundy, 43 N.Y.2d 838 (1978)
A qualified psychologist’s expert testimony regarding a defendant’s mental state is admissible, and it is an error of law to exclude such testimony solely because the witness is not a psychiatrist.
Summary
In a murder trial, the trial court erred by refusing to allow a psychologist to testify about whether the defendant was suffering from extreme emotional disturbance at the time of the killing, based solely on the fact that the witness was not a psychiatrist. The Court of Appeals held this was an error of law. While acknowledging the trial court’s discretion in determining expert witness qualifications, the court emphasized that barring a qualified psychologist’s testimony solely due to their lack of medical training was improper, potentially prejudicing the defendant’s ability to prove an affirmative defense. The dissent argued for reversal and a new trial.
Facts
The defendant was convicted of second-degree murder for killing his paramour.
At trial, the defense attempted to introduce testimony from a psychologist regarding the defendant’s mental state at the time of the killing, specifically, whether he was suffering from extreme emotional disturbance.
The trial court refused to allow the psychologist to testify, explicitly stating the opinion sought could only be given by a psychiatrist.
The psychologist was qualified and trained in interpreting tests and drawing conclusions but was not a medical doctor.
Procedural History
The trial court convicted the defendant of second-degree murder.
The Appellate Division affirmed the conviction.
The case was appealed to the New York Court of Appeals.
Issue(s)
Whether the trial court erred in refusing to allow a qualified psychologist to testify as an expert witness regarding the defendant’s mental state solely because the witness was not a psychiatrist.
Holding
Yes, because it is an error of law to exclude a qualified psychologist’s expert testimony regarding a defendant’s mental state solely because they are not a psychiatrist. Such exclusion may prejudice the defendant’s ability to present a defense.
Court’s Reasoning
The Court of Appeals, in a dissenting opinion by Judge Meyer, emphasized that the trial court’s ruling was based solely on the psychologist’s lack of medical training, not on a finding that the psychologist was unqualified based on insufficient training in psychology.
The court cited People v. Davis, 62 Cal. 2d 791, which held it was error to refuse a clinical psychologist’s testimony solely because of a lack of medical training. Justice Traynor stated in Davis, “A witness is qualified to testify about a matter calling for an expert opinion if his peculiar skill, training, or experience enable him to form an opinion that will be useful to the jury.”
The court noted that while there was not unanimous agreement on the admissibility of psychologist testimony on mental state, the prevailing view favored admissibility. This view aligns with the principle that an expert’s opinion should be received if they are truly an expert on the subject, regardless of medical licensure, as stated in People v Rice, 159 NY 400, 410.
Furthermore, CPL 730.10 (subd 8) and CPL 730.20 (subd 1) recognize “certified psychologists” as qualified “psychiatric examiners” competent to give opinions on a defendant’s mental capacity to stand trial.
Excluding the psychologist’s testimony could have prejudiced the defendant’s ability to prove the affirmative defense that he acted under extreme emotional disturbance. Therefore, the dissent argued for a reversal and a new trial to allow the jury to consider such evidence.
The dissent directly quoted from *People v. Davis*: “The alleged disability did not involve a matter of mental illness completely within the realm of a physician. A functional disorder is by definition nonorganic and without a biological cause. The trial court erred in ruling that only one with medical training could testify on the issue.”