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Keywords

defendanttrialprosecutorhung juryhearsay
defendanttrialcross-examinationhung juryhearsay

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People v. Goldstein, 6 N.Y.3d 119, 843 N.E.2d 727, 810 N.Y.S.2d 100, 2005 N.Y. Slip Op. 09654

Facts

On January 3, 1999, the defendant killed Kendra Webdale by throwing her into the path of an oncoming subway train. His defense was based on insanity, claiming he was suffering from schizophrenia at the time of the act. The first trial ended in a hung jury, and during the second trial, two forensic psychiatrists provided conflicting opinions on the defendant's mental state. The prosecution's psychiatrist, Angela Hegarty, was allowed to testify about hearsay statements from third parties, which the defendant argued violated his right to confront witnesses.

On January 3, 1999, defendant killed Kendra Webdale, a woman he did not know, by throwing her into the path of an approaching subway train. He was charged with murder in the second degree; his principal defense was insanity. His first trial ended in a hung jury.

Issue

Did the admission of hearsay statements made to the prosecution's psychiatrist violate the defendant's constitutional right to confront witnesses against him?

Did the admission of hearsay statements made to the prosecution's psychiatrist violate the defendant's constitutional right to confront witnesses against him?

Rule

The Confrontation Clause prohibits the use of testimonial hearsay against a defendant in a criminal case unless the defendant has the opportunity to cross-examine the out-of-court declarant.

The Sixth Amendment to the United States Constitution provides: 'In all criminal prosecutions, the accused shall enjoy the right … to be confronted with the witnesses against him.'

Analysis

The court determined that the statements made to Hegarty by her interviewees were testimonial hearsay, as they were made in the context of trial preparation and were intended to be used prosecutorially. The court concluded that the defendant's rights under the Confrontation Clause were violated when Hegarty was allowed to recount these statements without the defendant having the opportunity to cross-examine the interviewees.

In short, defendant's rights under the Confrontation Clause were violated when Hegarty was allowed to tell the jury what witnesses defendant had no chance to cross-examine had said to her.

Conclusion

The court reversed the defendant's conviction and ordered a new trial, emphasizing the importance of the right to confront witnesses.

Accordingly, the order of the Appellate Division should be reversed and the case remitted to Supreme Court for a new trial.

Who won?

Defendant prevailed because the court found that his constitutional right to confront witnesses was violated, necessitating a new trial.

Defendant prevailed because the court found that his constitutional right to confront the witnesses against him was violated when a psychiatrist who testified for the prosecution recounted statements made to her by people who were not available for cross-examination.

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