People v. Edney

39 N.Y.2d 620, 385 N.Y.S.2d 23, 350 N.E.2d 400 (1976)

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People v. Edney

New York Court of Appeals
39 N.Y.2d 620, 385 N.Y.S.2d 23, 350 N.E.2d 400 (1976)

  • Written by Nicole Gray , JD

Facts

Edney (plaintiff), who had a history of schizophrenia and alcoholism, kidnapped and brutally killed his former girlfriend’s eight-year-old daughter. When Edney was arrested, he told detectives that he had consumed a lot of alcohol and marijuana that night; he had been in the bar in front of the alley where the young girl’s body was found; and he may have killed the young girl but did not recall because he blacked out. The People of New York (the state) (defendant) charged Edney with first-degree manslaughter and first and second-degree kidnapping. Edney raised the defense of insanity. At trial, Edney introduced psychiatric evidence that severity of his mental illness prevented him from understanding the nature and quality of his actions. The state called a rebuttal psychiatrist who was also a lawyer, who had initially been hired by Edney’s counsel to examine Edney with the potential of serving as an expert witness on Edney’s behalf. Edney’s objections to the rebuttal psychiatrist’s testimony on the grounds that it was protected by physician-patient and attorney-client privileges were overruled. The rebuttal psychiatrist testified that Edney had alcoholic psychosis, which occasionally manifested in hallucinations and delusions, but it was his opinion that Edney did know and appreciate the consequences of his actions at the time of the murder. Edney was eventually convicted on all charges. The appellate division affirmed, and Edney appealed, re-urging that the state’s rebuttal psychiatrist’s testimony was privileged and barred from admission.

Rule of Law

Issue

Holding and Reasoning (Gabrielli, J.)

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