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defendanttrialverdict
defendantdue process

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People v. Angelo, 88 N.Y.2d 217, 666 N.E.2d 1333, 644 N.Y.S.2d 460

Facts

Defendant, a nurse, was charged with multiple counts of depraved indifference murder and assault for injecting seven patients with a neuromuscular blocking agent, leading to the deaths of six due to respiratory failure. At trial, he admitted to the conduct but claimed a mental illness prevented him from recognizing the risks involved. Two psychological experts testified that he suffered from a dissociative disorder, which impaired his awareness of the consequences of his actions.

Defendant was charged with multiple counts of second degree murder (depraved indifference murder) and assault in connection with the unauthorized injection of seven patients with a neuromuscular blocking agent at the hospital at which he was employed as a nurse, resulting in the deaths of six of them from respiratory failure.

Issue

Did the trial court err in excluding polygraph evidence and in submitting an annotated verdict sheet to the jury?

1 Defendant argues that County Court erred in prohibiting Dr. Schwartz from testifying that his conclusions were based in part on the results of defendant's polygraph examination and that the court's ruling violated his constitutional rights to due process and to present witnesses in his own defense.

Rule

Polygraph evidence is inadmissible unless it is shown to be scientifically accepted, and a verdict sheet must not contain annotations unless consented to by the parties.

Polygraph testing inadmissible as scientifically unreliable.

Analysis

The court determined that the trial court correctly excluded the polygraph evidence because the defendant did not demonstrate that such evidence is generally accepted as reliable in the scientific community. Furthermore, the court found that the annotated verdict sheet was submitted with the defense counsel's approval, negating any claim of error.

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.

Conclusion

The court affirmed the Appellate Division's decision, upholding the defendant's convictions and the trial court's rulings.

Accordingly, the order of the Appellate Division should be affirmed.

Who won?

The People (State of New York) prevailed as the court upheld the defendant's convictions and the trial court's evidentiary rulings.

Defendant was ultimately convicted of two counts of depraved indifference murder, one count of second degree manslaughter, one count of criminally negligent homicide and six counts of assault with respect to five of the patients and was sentenced accordingly.

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