Exculpatory Evidence: People v. Hayes

New York State Court of Appeals
Exculpatory Evidence

Cross-Examination

People v. Hayes
No. 79
Judge Jones

Background: The court addressed two issues.  The first was whether the failure of the police to interview witnesses after overhearing two potentially exculpatory statements constituted a Brady violation. The second was whether the defendant was improperly precluded during cross-examination from challenging the adequacy of the police investigation.

Ruling: With respect to the first issue, the court declined to deviate from precedent as doing so would place an affirmative duty on the police to obtain exculpatory evidence for defendants.  Therefore, the actions of the police did not violate the requirements of Brady. The court held that the trial court did not abuse its discretion by limiting the scope of cross-examination as the testimony to be elicited was hearsay and its probative force was outweighed by the dangers of speculation, confusion and prejudice.

John Schoeffel for the appellant; Gina Mignola for the respondent