New York Law Review

Tag: polygraph

  • People v. Angelo, 88 N.Y.2d 217 (1996): Admissibility of Polygraph Evidence in Criminal Trials

    People v. Angelo, 88 N.Y.2d 217 (1996)

    Polygraph test results are inadmissible as evidence in New York criminal trials because they are not generally accepted within the scientific community as reliable.

    Summary

    Angelo, a nurse, was convicted of murder and assault for injecting patients with a neuromuscular blocking agent. At trial, he argued a mental illness prevented him from understanding the risk of his actions. He sought to introduce polygraph results, arguing they supported his expert’s diagnosis. The trial court excluded the polygraph evidence, citing its unreliability. The Court of Appeals affirmed, holding that polygraph results are inadmissible unless generally accepted as reliable in the scientific community, which Angelo failed to demonstrate. This case reinforces the application of the *Frye* standard in New York, requiring scientific reliability for novel scientific evidence.

    Facts

    Angelo, a nurse, injected seven patients with a neuromuscular blocking agent, leading to six deaths. He claimed a dissociative disorder prevented him from understanding the risk his actions posed to the patients. Angelo sought to prove that he had feelings of inadequacy, and injected patients so he could then participate in their resuscitation, unaware that his injections caused their distress.

    Procedural History

    Angelo was convicted of murder, manslaughter, criminally negligent homicide, and assault. The Appellate Division affirmed. The New York Court of Appeals granted leave to appeal.

    Issue(s)

    Whether the trial court erred in prohibiting Angelo’s expert from testifying that his conclusions were based, in part, on the results of Angelo’s polygraph examination.

    Holding

    No, because polygraph test results are not generally accepted by the scientific community as reliable and therefore are inadmissible as evidence.

    Court’s Reasoning

    The Court of Appeals upheld the trial court’s decision to exclude the polygraph evidence. The Court reasoned that while experts can rely on out-of-court evidence, that evidence must be “of a kind accepted in the profession as reliable in forming a professional opinion” or “comes from a witness subject to full cross-examination on the trial” (citing People v. Sugden, 35 N.Y.2d 453, 460-461). This incorporates the *Frye* standard, requiring general acceptance of the scientific procedures and methodology. Because Angelo failed to demonstrate that polygraph test results meet this standard, the evidence was properly excluded.
    Specifically, the Court stated, “Because defendant did not demonstrate that polygraph test results are generally accepted by the scientific community as reliable, County Court did not err in excluding defendant’s polygraph results.”
    The court also noted that Angelo did not properly preserve his argument that a *Frye* hearing should have been held, as he did not definitively request such a hearing or argue that the scientific consensus had changed since previous rulings deeming polygraph evidence inadmissible.
    Finally, the Court rejected Angelo’s argument that the validity of the test results was not at issue, clarifying that because the polygraph was offered to prove the honesty of Angelo’s belief, its probative value depended on the reliability of the test results.

  • People v. Leone, 25 N.Y.2d 511 (1969): Admissibility of Polygraph Test Results in Criminal Trials

    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.