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Keywords

defendantappealtrialtestimonyrelevanceadmissibilitycredibility

defendantjurisdictionarraignmentprosecutor

Related Cases

People v. Mountain, 66 N.Y.2d 197, 486 N.E.2d 802, 495 N.Y.S.2d 944

Facts

In the early morning hours of September 12, 1981, a young woman was arrested by the Schenectady Police and held in a detention cell. During her detention, the defendant, who was a police officer at the station, approached her multiple times and eventually assaulted her. After the incident, the victim reported the rape and provided a specimen containing sperm, which was later tested and found to contain type A blood. The defendant was indicted for rape, sodomy, and official misconduct, and the trial included various evidentiary disputes regarding the admissibility of blood type evidence and the victim's credibility.

The defendant, a former police officer, has been convicted of raping and sodomizing a woman being held for arraignment in a detention cell at a police station.

Issue

The main legal issues included whether the court erred in admitting evidence regarding the blood type of the sperm found in the victim and whether the trial court improperly excluded evidence related to the defendant's holster.

The primary issue concerns efforts by the prosecutor to establish a relationship between the defendant's blood type and the blood type found in the assailant's sperm, a procedure universally accepted in other jurisdictions but previously not allowed in this State in cases, such as this, where the blood type is a common one.

Rule

The court applied the principle that evidence of blood type can be admissible if it is relevant and not prejudicial, and that the credibility of witnesses can be bolstered by relevant evidence.

In the Robinson case this court stated at page 865, 317 N.Y.S.2d 19, 265 N.E.2d 543: “Proof that the defendant had type ‘A’ blood and that the semen found in and on the body of the decedent was derived from a man with type ‘A’ blood was ***947 of no probative value in the case against defendant in view of the large proportion of the general population having blood of this type and, therefore, should not have been admitted”.

Analysis

The court found that the defendant was not prejudiced by the admission of the blood type evidence because the jury was informed that the defendant's blood type was not in evidence. Additionally, the court ruled that the evidence regarding the victim's intention to donate any civil suit proceeds was relevant to counter the defendant's claims of a pecuniary motive for her testimony. The exclusion of the holster was deemed appropriate as the defendant failed to establish a proper foundation for its relevance to the case.

Thus, the Robinson rule goes too far in holding that evidence showing that the defendant and the assailant have type A blood, is of no probative value merely because that includes 40% of the population ( see, Matter of Abe A., supra, 56 N.Y.2d at p. 299, n. 4, 452 N.Y.S.2d 6, 437 N.E.2d 265).

Conclusion

The Court of Appeals affirmed the Appellate Division's decision, concluding that the defendant was not prejudiced by the evidentiary rulings made during the trial.

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

Who won?

The People (the prosecution) prevailed in the case as the court upheld the defendant's conviction, finding no reversible error in the trial court's evidentiary decisions.

The Appellate Division unanimously affirmed ( 105 A.D.2d 494, 481 N.Y.S.2d 449).

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