People v. Freshley, 27 N.Y.2d 241 (1970)

The mere fact that a witness has a history of mental illness does not automatically disqualify them from testifying, but the jury should be made aware of the witness’s condition to properly evaluate their testimony.

Summary

Freshley was convicted of first-degree murder for the shooting death of Arthur Holst. His codefendant, Krombholz, testified against him. After the verdict but before sentencing, Krombholz was declared legally insane and committed to a mental hospital. Freshley moved for a new trial based on newly discovered evidence of Krombholz’s long history of mental illness, arguing that this information would have significantly impacted the jury’s assessment of Krombholz’s credibility. The Court of Appeals reversed the conviction, holding that the jury should have been aware of Krombholz’s mental condition to properly evaluate his testimony, especially in a capital case.

Facts

Arthur Holst was found dead in the basement of the ice cream parlor where he worked, shot twice in the chest.
Freshley, the manager of the store, admitted to the murder and implicated Krombholz, claiming his employer instructed him to kill Holst for stealing money.
Krombholz testified against Freshley, directly implicating him in the crime.
After the jury’s verdict, Krombholz was found to be legally insane with a longstanding mental illness and committed to Matteawan State Hospital.
Krombholz had a history of mental illness, including a head injury, brain operation, and multiple hospitalizations for mental illness diagnosed as Paranoid Schizophrenia.

Procedural History

Freshley was convicted of first-degree murder in the Supreme Court, Kings County.
He moved for a new trial based on newly discovered evidence of Krombholz’s mental illness.
The trial court denied the motion, finding that Krombholz appeared competent to testify and that his testimony did not materially affect the verdict.
Freshley appealed to the New York Court of Appeals.

Issue(s)

Whether the trial court erred in denying Freshley’s motion for a new trial based on newly discovered evidence of Krombholz’s long history of mental illness, which was not disclosed to the jury during the trial.

Holding

Yes, because the jury should have been made aware of Krombholz’s mental condition to properly assess his credibility, especially in a case where the punishment is death.

Court’s Reasoning

The court acknowledged that a person’s mental illness does not automatically disqualify them from testifying. A witness is competent to testify if they understand the nature of an oath and can give a reasonably accurate account of events.
However, the court emphasized that the jury should have been informed of Krombholz’s mental condition so they could properly evaluate his testimony. The court stated, “what would have been the reactions of the jurors had they been made aware that there was ‘something mentally wrong’ with Krombholz and had they known that he had ‘visual and auditory hallucinations with marked memory defect’, that he had been diagnosed ‘as a case of Paranoid Schizophrenia’ and that he had been discharged from a sanitarium in 1950 ‘against medical advice’?”
Without this knowledge, the jury would have accepted Krombholz’s testimony as that of a “normal” individual, which was not the case.
Unlike People v. Salemi, where the jury was aware of the witness’s mental instability, in this case, the jury had no indication that Krombholz suffered from a long-standing mental illness. Therefore, the court held that Freshley was entitled to a new trial in the interests of justice.