State v. Floyd Y.
22 N.Y.3d 95
| NY | 2013Background
- Floyd Y. was convicted in 2001 of multiple counts of sexual abuse and endangering a child and later faced a civil article 10 proceeding.
- The State sought to admit expert testimony based on hearsay to establish mental abnormality under SOMTA; Floyd Y. moved to exclude basis hearsay.
- Drs. Mortiere and Kunz testified; Mortiere relied on numerous uncharged/uncorroborated accusations and hearsay in forming opinions.
- The trial court admitted basis hearsay with limiting instructions; the Appellate Division partially upheld reliability of some basis evidence but excluded others.
- Floyd Y. appealed arguing due process and psychologist-patient privilege concerns; the Appellate Division order was ultimately appealed to this Court.
- The Court reversed, ordering a new trial, finding certain basis hearsay unreliable or unduly prejudicial and addressing due process
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether basis hearsay in expert opinion violates due process | Floyd Y. argues due process requires reliability; basis hearsay should be excluded | State contends some basis hearsay is admissible if reliable and probative for expert opinion | Yes, basis hearsay must meet reliability and probative value outweigh prejudicial effect |
| Civil article 10 proceedings are subjected to due process and Mathews test | Article 10 is quasi-criminal; due process requires confrontation rights | Proceedings are civil; Mathews test applies with balancing | Mathews test applies but due process requires reliability scrutiny of basis evidence |
| Whether basis hearsay can be admitted under professional reliability | Wagman and NY law prohibit disclosure of contents of basis hearsay | Professional reliability exception allows reliance on hearsay for opinion | Basis hearsay generally inadmissible; not permitted to disclose contents to jury |
| Confrontation rights in article 10 proceedings | Floyd Y. lacks confrontation rights; cross-examination of declarants is essential | Civil context limits confrontation; due process balances differently | Confrontation rights apply comparably to criminal defendants; new trial ordered |
Key Cases Cited
- People v Goldstein, 6 NY3d 119 (2005) (basis hearsay and expert reliance; confrontation concerns)
- Wagman v. Bradshaw, 292 AD2d 84 (2d Dept 2002) (expert may rely on inadmissible information for opinion but not disclose contents)
- People v. Crimmins, 36 NY2d 230 (1975) (harmless error and prejudice analysis for evidentiary errors)
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (Confrontation Clause; reliability and confrontation in evidentiary usage)
- Allen v. Illinois, 478 U.S. 364 (U.S. 1986) (civil commitment context; due process in confinement proceedings)
- Addington v. Texas, 441 U.S. 418 (U.S. 1979) (due process in civil commitment; Mathews v Eldridge framework)