Trial Testimony - Right to Interpreter for Person Who Can Not Communicate with Court
As a corollary to the right to counsel, non-English speaking individuals have the right to an interpreter to enable them to participate meaningfully in their trial and assist in their own defense. [1]
To facilitate this right the Judiciary Law provides for the appointment and temporary appointment of court interpreters [2] and provides for the appointment of interpreters for deaf persons.[3] In addition, the court rules provide that “In all civil and criminal cases, when a court determines that a party or witness, or an interested parent or guardian in a Family Court proceeding, is unable to understand or communicate to the extent that he or she cannot meaningfully participate in the proceedings, the court shall appoint an interpreter”.[4]
The failure to provide an interpreter where one is needed renders the trial constitutionally defective.[5] Where trial court is put on notice that the defendant has severe difficulty in understanding the English language, it must inform him that he has the right to a competent translator to assist him, at the state's expense, if he cannot afford one.[6]
The determination whether a court-appointed interpreter is necessary lies within the sound discretion of the trial court,[7] which is in the best position to make the fact-intensive inquiries necessary to determine whether there exists a language barrier such that the failure to appoint an interpreter will deprive the defendant of his or her constitutional rights. [8]
The determination of the qualifications of an interpreter for a non-English speaking witness or a deaf party is within the sound discretion of trial court.[9]
Upon being appointed to act in a given case, a temporary interpreter is required to “file with the clerk of the court the constitutional oath of office."[10]
It is error for the court to allow a relative to interpret for a witness without first determining the need for the appointment of an interested person, inquiring into the extent of his bias, ascertaining his qualifications to translate, and admonishing him that he must translate exactly what the primary witness had said. An interpreter should be one who has no bias or interest in the outcome of a case. This is so because the danger that a primary witness' message will be distorted through interpretation is compounded when the interpreter is biased one way or the other. It has been termed the better practice to avoid appointing a friend or relative of a party or witness as interpreter. [11]
Many cases recognize that it sometimes may be necessary to appoint an interested interpreter, where no competent disinterested interpreter is available. Such an interested person should not be utilized unless and until the trial judge is satisfied that no disinterested person is available who can adequately translate the primary witness' testimony. Even where the court permissibly appoints an interested interpreter, the Trial Judge must interrogate him in order to gauge the extent of his bias and admonish him that he must translate exactly what the primary witness has said.[12]
The interpreter must translate exactly what the witness has said. He may not paraphrase the witness testimony.[13] Since the interpreter is the conduit from the witness to the trier-of-fact, interpretation should be word-for-word rather than summarized, and there should be no conversation between the witness and the interpreter, and no significant differences in the length of dialogue of the witness and the interpreter. [14]
The Office of Court Administration has issued a “bench card” for Judges working with interpreters in the courtroom, alerting judges to assess: 1. Are there significant differences in the length of interpretation as compared to the original testimony? 2. Does the individual needing the interpreter appear to be asking questions of the interpreter? 3. Is the interpreter leading the witness, or trying to influence answers through body language or facial expressions? 4. Is the interpreter acting in a professional manner? 5. Is the interpretation being done in the first person? 6. If the interpreter has a question, does he or she address the court in the third-person?[15]
It has been held that the failure of the defendant to object as to the adequacy of the translation during the trial or otherwise preserve proof of any serious error does not provide the basis for a reversal.[16]
Reversal is not required where there are errors in translation if the errors do not prejudice the rights of a party.[17]
An interpreter may be appointed by the court, in proper circumstances, where a witness has difficulty communicating to the court. In Matter of Luz P, [18]a child protective proceeding the Appellate Division considered the proper course to be taken by a trial court when confronted with a potential witness who suffered from a disability in communicating. The court, sua sponte, raised the question of whether autism prevented Luz from being sui juris. The Appellate Division observed that all questions of competence are to be decided preliminarily by the court alone. At common law, a non-verbal or mute witness such as Luz would have been disqualified from testifying; however, that is no longer the rule and a deaf mute, similar to a witness unable to speak English, may testify through a person who can understand and communicate with the witness. A critical consideration in the appointment of an interpreter for a witness who does not speak in the English language is a matching of the level of communication skill of the witness with that of the interpreter. When dealing with foreign languages, there are differences in dialects that could render translations unreliable or even unintelligible. Similarly, communicating with witnesses who have profound hearing and/or speech impairments can be complicated by the variety of "signing" systems that are in use. The test for the court in cases such as these is a pragmatic one. Can the interpreter, or in this case the facilitator, effectively communicate with the witness and reliably convey the witness's answers to the court? A determination of these questions does not require expert testimony. The proffered facilitated communication lends itself to empirical rather than scientific proof. Thus, the test whereby the court could question Luz outside the presence of the facilitator and then hear her responses through facilitated communication should adequately establish whether this is a reliable and accurate means of communication by Luz. Fact-specific questions can be devised which should demonstrate whether the answers are subject to the influence, however subtle, of the facilitator. If the court is satisfied from this demonstration that the facilitator is "qualified" to transmit communications from Luz to the court, then the facilitator may be appointed as an interpreter under Judiciary Law article 12. The Appellate Division held that the facilitated communication proffered need not satisfy the requirements of the Frye test.[19] The rule laid down in Frye provides that scientific evidence will only be admitted at trial if the procedure and results are generally accepted as reliable in the scientific community. Since the ability of an interpreter, translator, "signer”, or anyone else who transmits the testimony of a witness is not based on a scientific theory, any application of the Frye test is inapposite. Inasmuch as such a preliminary showing was not necessary with regard to the interpreter and the respondent (Spanish) parents, there was similarly no basis for concluding that the presentation of expert scientific evidence is necessary with respect to Luz's facilitator, who would only assist her in communicating her responses to the court and would not translate any of the questions put to Luz. The better position, in its view, was set forth in Matter of Marshall R.[20] In that case, the Appellate Division reversed the dismissal of a child abuse and neglect petition because the Family Court ruled that an out of court statement made by a six-year-old deaf child could not be testified to by an interpreter for the deaf. In language that was equally applicable to this case, the court observed: "The best interests of the child are far more important than some technical objection which, on this record, appears to have little substance. The testimony of the interpreter should have been admitted, and then it would become the duty of the court to weigh and evaluate such testimony in the light of the circumstances under which it was given.” The Appellate Division observed that the court must be satisfied that the testimony as transmitted by facilitation is the testimony of Luz herself, uninfluenced by the facilitator. If the court is not convinced that the facilitator is reliable, then that facilitator may not serve as the interpreter. However, such a finding should not foreclose Luz from testifying if a reliable facilitator could be found elsewhere. The DSS would have the burden of establishing the reliability of the facilitator at the preliminary proceeding. Furthermore, the fact that Luz had been diagnosed as autistic and classified as retarded did not preclude her from testifying provided she understood the nature and obligations of the oath, and provided, also, she possessed the capacity to give a correct account of what she had seen or heard in reference to the question at issue. This challenge must be decided by the court preliminarily. To this end, the court may examine not only the proposed witness but anyone else who could aid in the resolution of the issue. However, inasmuch as proposed witnesses are presumed competent, it would be the burden of the respondents to demonstrate that Luz lacked the capacity to testify by reason of her autism or purported mental retardation.
The right to an interpreter may be waived where a defendant, or his attorney, fails to call to the attention of the trial court, in some appropriate manner, the fact that he or she does not possess sufficient understanding of the English language.[21] "In the absence of an obvious manifestation to the court of a defendant's lack of understanding of the English language, or a specific request to the court based on this misunderstanding, there is no obligation upon the court to provide a defendant with an interpreter" [22]
[1] Matter of Er-Mei Y., 29 A.D.3d 1013, 816 N.Y.S.2d 539 (2d Dept 2006
[2] Judiciary Law §387. Temporary appointment of interpreters
If the services of an interpreter be required in any court and there be no unemployed official interpreter to act therein, the court may appoint an interpreter to act temporarily in such court. Such interpreter shall before entering upon his duties file with the clerk of the court the constitutional oath of office. The court shall fix the compensation of such interpreter at not more than twenty-five dollars per day for each day's actual attendance by direction of the presiding judge or justice and such compensation shall be paid from the court fund of the county upon the order of the court.
See also 28 U.S.C.A. § 1827. Interpreters in courts of the United States
[3] Judiciary Law § 390; People v. Doe, 158 Misc.2d 863, 602 N.Y.S.2d 507 (1993) held that a hearing impaired defendant was entitled to the services of interpreter to assist in her defense, as matter of due process, even assuming that she was able to hear 92% of trial.
[4] 22 NYCRR 217
[5] People v. Johnny P., 112 Misc.2d 647, 445 N.Y.S.2d 1007 (1981).
[6] People v. DeArmas, 106 A.D.2d 659, 483 N.Y.S.2d 121 (2d Dept 1884)
[7] In re Ejoel M., 34 A.D.3d 678, 824 N.Y.S.2d 660 (2 Dept 2006)
[8] In re Edward N., 51 A.D.3d 928, 858 N.Y.S.2d 723 (2 Dept 1988) (citing People v. Warcha, 17 A.D.3d 491, 493, 792 N.Y.S.2d 627)
[9] People v. Catron, 143 A.D.2d 468, 532 N.Y.S.2d 589 (3d Dept 1988).
In People v. Miller, 140 Misc.2d 247, 530 N.Y.S.2d 490 (1988) a speech therapist was qualified to act as "interpreter" for the complainant who suffered from severe cerebral palsy. The therapist demonstrated ability to understand that witness and to translate his responses word for word.
[10] See Judiciary Law §§386 and 387
[11] Matter of James L, 143 A.D.2d 533, 532 N.Y.S.2d 941 (4 Dept. 1988)
[12] Id.
[13] Id.
[14] See, e.g., Matter of James L., 143 A.D.2d 533, 532 N.Y.S.2d 941; see also, Dat Pham v. Beaver, 445 F.Supp.2d 252 (W.D.N.Y. 2006); US v. Joshi, 896 F.2d 1303 (11 Cir 1990); In re Yovanny, L. 33 Misc.3d 894, 931 N.Y.S.2d 485 (Fam Ct., 2011).
See also U.S. v. Joshi, 896 F.2d 1303 (11th Cir 1990) (Under Court Interpreters Act, the general standard for adequate translation of trial proceedings requires continuous word-for-word translation of everything relating to trial a defendant conversant in English would be privy to hear; however, occasional lapses from this standard, particularly when they are not objected to by defendant, will not render trial fundamentally unfair.)
[15] In re Yovanny, L., 33 Misc.3d 894, 931 N.Y.S.2d 485 (Fam Ct., 2011)
[16] See People v. Ko, 133 A.D.2d 850, 520 N.Y.S.2d 412; People v. Rolston, 109 A.D.2d 854, 486 N.Y.S.2d 768.
[17] In People v. Singleton, 59 A.D.3d 1131, 873 N.Y.S.2d 838, the Court held that while there were some errors in interpretation, the defendant failed to establish that he “was prejudiced by those errors”, and the conviction was affirmed.
In People v. Dat Pham, 283 A.D.2d 952, 725 N.Y.S.2d 245, while there were some errors in the translation, the jury was informed of the errors, and the conviction was affirmed because the defendant did not show that he was seriously prejudiced.
[18] 189 A.D.2d 274, 595 N.Y.S.2d 541 (2d Dept 1993)
[19] Frye v. United States, 293 F. 1013.
[20] 73 A.D.2d 988, 423 N.Y.S.2d 564.
[21] Catholic Guardian Soc. of Diocese of Brooklyn, Inc. (Ricardo V.) v. Elba V. 216 A.D.2d 558, 628 N.Y.S.2d 796 (2d Dept 1995)
[22] Catholic Guardian Soc. of Diocese of Brooklyn, Inc. (Ricardo V.) v. Elba V. 216 A.D.2d 558, 628 N.Y.S.2d 796 (2d Dept 1995) (citing People v. Ramos, 26 N.Y.2d 272, 274-75, 309 N.Y.S.2d 906, 258 N.E.2d 197; see also, Matter of Vladimir M., 206 A.D.2d 482, 614 N.Y.S.2d 572; People v. Calizaire, 190 A.D.2d 857, 593 N.Y.S.2d 879; People v. Gamal, 148 A.D.2d 468, 538 N.Y.S.2d 620; People v. Navarro, 134 A.D.2d 460, 521 N.Y.S.2d 82; Matter of Jose R., 49 A.D.2d 869,376 N.Y.S.2d 906).
As a corollary to the right to counsel, non-English speaking individuals have the right to an interpreter to enable them to participate meaningfully in their trial and assist in their own defense. [1]
To facilitate this right the Judiciary Law provides for the appointment and temporary appointment of court interpreters [2] and provides for the appointment of interpreters for deaf persons.[3] In addition, the court rules provide that “In all civil and criminal cases, when a court determines that a party or witness, or an interested parent or guardian in a Family Court proceeding, is unable to understand or communicate to the extent that he or she cannot meaningfully participate in the proceedings, the court shall appoint an interpreter”.[4]
The failure to provide an interpreter where one is needed renders the trial constitutionally defective.[5] Where trial court is put on notice that the defendant has severe difficulty in understanding the English language, it must inform him that he has the right to a competent translator to assist him, at the state's expense, if he cannot afford one.[6]
The determination whether a court-appointed interpreter is necessary lies within the sound discretion of the trial court,[7] which is in the best position to make the fact-intensive inquiries necessary to determine whether there exists a language barrier such that the failure to appoint an interpreter will deprive the defendant of his or her constitutional rights. [8]
The determination of the qualifications of an interpreter for a non-English speaking witness or a deaf party is within the sound discretion of trial court.[9]
Upon being appointed to act in a given case, a temporary interpreter is required to “file with the clerk of the court the constitutional oath of office."[10]
It is error for the court to allow a relative to interpret for a witness without first determining the need for the appointment of an interested person, inquiring into the extent of his bias, ascertaining his qualifications to translate, and admonishing him that he must translate exactly what the primary witness had said. An interpreter should be one who has no bias or interest in the outcome of a case. This is so because the danger that a primary witness' message will be distorted through interpretation is compounded when the interpreter is biased one way or the other. It has been termed the better practice to avoid appointing a friend or relative of a party or witness as interpreter. [11]
Many cases recognize that it sometimes may be necessary to appoint an interested interpreter, where no competent disinterested interpreter is available. Such an interested person should not be utilized unless and until the trial judge is satisfied that no disinterested person is available who can adequately translate the primary witness' testimony. Even where the court permissibly appoints an interested interpreter, the Trial Judge must interrogate him in order to gauge the extent of his bias and admonish him that he must translate exactly what the primary witness has said.[12]
The interpreter must translate exactly what the witness has said. He may not paraphrase the witness testimony.[13] Since the interpreter is the conduit from the witness to the trier-of-fact, interpretation should be word-for-word rather than summarized, and there should be no conversation between the witness and the interpreter, and no significant differences in the length of dialogue of the witness and the interpreter. [14]
The Office of Court Administration has issued a “bench card” for Judges working with interpreters in the courtroom, alerting judges to assess: 1. Are there significant differences in the length of interpretation as compared to the original testimony? 2. Does the individual needing the interpreter appear to be asking questions of the interpreter? 3. Is the interpreter leading the witness, or trying to influence answers through body language or facial expressions? 4. Is the interpreter acting in a professional manner? 5. Is the interpretation being done in the first person? 6. If the interpreter has a question, does he or she address the court in the third-person?[15]
It has been held that the failure of the defendant to object as to the adequacy of the translation during the trial or otherwise preserve proof of any serious error does not provide the basis for a reversal.[16]
Reversal is not required where there are errors in translation if the errors do not prejudice the rights of a party.[17]
An interpreter may be appointed by the court, in proper circumstances, where a witness has difficulty communicating to the court. In Matter of Luz P, [18]a child protective proceeding the Appellate Division considered the proper course to be taken by a trial court when confronted with a potential witness who suffered from a disability in communicating. The court, sua sponte, raised the question of whether autism prevented Luz from being sui juris. The Appellate Division observed that all questions of competence are to be decided preliminarily by the court alone. At common law, a non-verbal or mute witness such as Luz would have been disqualified from testifying; however, that is no longer the rule and a deaf mute, similar to a witness unable to speak English, may testify through a person who can understand and communicate with the witness. A critical consideration in the appointment of an interpreter for a witness who does not speak in the English language is a matching of the level of communication skill of the witness with that of the interpreter. When dealing with foreign languages, there are differences in dialects that could render translations unreliable or even unintelligible. Similarly, communicating with witnesses who have profound hearing and/or speech impairments can be complicated by the variety of "signing" systems that are in use. The test for the court in cases such as these is a pragmatic one. Can the interpreter, or in this case the facilitator, effectively communicate with the witness and reliably convey the witness's answers to the court? A determination of these questions does not require expert testimony. The proffered facilitated communication lends itself to empirical rather than scientific proof. Thus, the test whereby the court could question Luz outside the presence of the facilitator and then hear her responses through facilitated communication should adequately establish whether this is a reliable and accurate means of communication by Luz. Fact-specific questions can be devised which should demonstrate whether the answers are subject to the influence, however subtle, of the facilitator. If the court is satisfied from this demonstration that the facilitator is "qualified" to transmit communications from Luz to the court, then the facilitator may be appointed as an interpreter under Judiciary Law article 12. The Appellate Division held that the facilitated communication proffered need not satisfy the requirements of the Frye test.[19] The rule laid down in Frye provides that scientific evidence will only be admitted at trial if the procedure and results are generally accepted as reliable in the scientific community. Since the ability of an interpreter, translator, "signer”, or anyone else who transmits the testimony of a witness is not based on a scientific theory, any application of the Frye test is inapposite. Inasmuch as such a preliminary showing was not necessary with regard to the interpreter and the respondent (Spanish) parents, there was similarly no basis for concluding that the presentation of expert scientific evidence is necessary with respect to Luz's facilitator, who would only assist her in communicating her responses to the court and would not translate any of the questions put to Luz. The better position, in its view, was set forth in Matter of Marshall R.[20] In that case, the Appellate Division reversed the dismissal of a child abuse and neglect petition because the Family Court ruled that an out of court statement made by a six-year-old deaf child could not be testified to by an interpreter for the deaf. In language that was equally applicable to this case, the court observed: "The best interests of the child are far more important than some technical objection which, on this record, appears to have little substance. The testimony of the interpreter should have been admitted, and then it would become the duty of the court to weigh and evaluate such testimony in the light of the circumstances under which it was given.” The Appellate Division observed that the court must be satisfied that the testimony as transmitted by facilitation is the testimony of Luz herself, uninfluenced by the facilitator. If the court is not convinced that the facilitator is reliable, then that facilitator may not serve as the interpreter. However, such a finding should not foreclose Luz from testifying if a reliable facilitator could be found elsewhere. The DSS would have the burden of establishing the reliability of the facilitator at the preliminary proceeding. Furthermore, the fact that Luz had been diagnosed as autistic and classified as retarded did not preclude her from testifying provided she understood the nature and obligations of the oath, and provided, also, she possessed the capacity to give a correct account of what she had seen or heard in reference to the question at issue. This challenge must be decided by the court preliminarily. To this end, the court may examine not only the proposed witness but anyone else who could aid in the resolution of the issue. However, inasmuch as proposed witnesses are presumed competent, it would be the burden of the respondents to demonstrate that Luz lacked the capacity to testify by reason of her autism or purported mental retardation.
The right to an interpreter may be waived where a defendant, or his attorney, fails to call to the attention of the trial court, in some appropriate manner, the fact that he or she does not possess sufficient understanding of the English language.[21] "In the absence of an obvious manifestation to the court of a defendant's lack of understanding of the English language, or a specific request to the court based on this misunderstanding, there is no obligation upon the court to provide a defendant with an interpreter" [22]
[1] Matter of Er-Mei Y., 29 A.D.3d 1013, 816 N.Y.S.2d 539 (2d Dept 2006
[2] Judiciary Law §387. Temporary appointment of interpreters
If the services of an interpreter be required in any court and there be no unemployed official interpreter to act therein, the court may appoint an interpreter to act temporarily in such court. Such interpreter shall before entering upon his duties file with the clerk of the court the constitutional oath of office. The court shall fix the compensation of such interpreter at not more than twenty-five dollars per day for each day's actual attendance by direction of the presiding judge or justice and such compensation shall be paid from the court fund of the county upon the order of the court.
See also 28 U.S.C.A. § 1827. Interpreters in courts of the United States
[3] Judiciary Law § 390; People v. Doe, 158 Misc.2d 863, 602 N.Y.S.2d 507 (1993) held that a hearing impaired defendant was entitled to the services of interpreter to assist in her defense, as matter of due process, even assuming that she was able to hear 92% of trial.
[4] 22 NYCRR 217
[5] People v. Johnny P., 112 Misc.2d 647, 445 N.Y.S.2d 1007 (1981).
[6] People v. DeArmas, 106 A.D.2d 659, 483 N.Y.S.2d 121 (2d Dept 1884)
[7] In re Ejoel M., 34 A.D.3d 678, 824 N.Y.S.2d 660 (2 Dept 2006)
[8] In re Edward N., 51 A.D.3d 928, 858 N.Y.S.2d 723 (2 Dept 1988) (citing People v. Warcha, 17 A.D.3d 491, 493, 792 N.Y.S.2d 627)
[9] People v. Catron, 143 A.D.2d 468, 532 N.Y.S.2d 589 (3d Dept 1988).
In People v. Miller, 140 Misc.2d 247, 530 N.Y.S.2d 490 (1988) a speech therapist was qualified to act as "interpreter" for the complainant who suffered from severe cerebral palsy. The therapist demonstrated ability to understand that witness and to translate his responses word for word.
[10] See Judiciary Law §§386 and 387
[11] Matter of James L, 143 A.D.2d 533, 532 N.Y.S.2d 941 (4 Dept. 1988)
[12] Id.
[13] Id.
[14] See, e.g., Matter of James L., 143 A.D.2d 533, 532 N.Y.S.2d 941; see also, Dat Pham v. Beaver, 445 F.Supp.2d 252 (W.D.N.Y. 2006); US v. Joshi, 896 F.2d 1303 (11 Cir 1990); In re Yovanny, L. 33 Misc.3d 894, 931 N.Y.S.2d 485 (Fam Ct., 2011).
See also U.S. v. Joshi, 896 F.2d 1303 (11th Cir 1990) (Under Court Interpreters Act, the general standard for adequate translation of trial proceedings requires continuous word-for-word translation of everything relating to trial a defendant conversant in English would be privy to hear; however, occasional lapses from this standard, particularly when they are not objected to by defendant, will not render trial fundamentally unfair.)
[15] In re Yovanny, L., 33 Misc.3d 894, 931 N.Y.S.2d 485 (Fam Ct., 2011)
[16] See People v. Ko, 133 A.D.2d 850, 520 N.Y.S.2d 412; People v. Rolston, 109 A.D.2d 854, 486 N.Y.S.2d 768.
[17] In People v. Singleton, 59 A.D.3d 1131, 873 N.Y.S.2d 838, the Court held that while there were some errors in interpretation, the defendant failed to establish that he “was prejudiced by those errors”, and the conviction was affirmed.
In People v. Dat Pham, 283 A.D.2d 952, 725 N.Y.S.2d 245, while there were some errors in the translation, the jury was informed of the errors, and the conviction was affirmed because the defendant did not show that he was seriously prejudiced.
[18] 189 A.D.2d 274, 595 N.Y.S.2d 541 (2d Dept 1993)
[19] Frye v. United States, 293 F. 1013.
[20] 73 A.D.2d 988, 423 N.Y.S.2d 564.
[21] Catholic Guardian Soc. of Diocese of Brooklyn, Inc. (Ricardo V.) v. Elba V. 216 A.D.2d 558, 628 N.Y.S.2d 796 (2d Dept 1995)
[22] Catholic Guardian Soc. of Diocese of Brooklyn, Inc. (Ricardo V.) v. Elba V. 216 A.D.2d 558, 628 N.Y.S.2d 796 (2d Dept 1995) (citing People v. Ramos, 26 N.Y.2d 272, 274-75, 309 N.Y.S.2d 906, 258 N.E.2d 197; see also, Matter of Vladimir M., 206 A.D.2d 482, 614 N.Y.S.2d 572; People v. Calizaire, 190 A.D.2d 857, 593 N.Y.S.2d 879; People v. Gamal, 148 A.D.2d 468, 538 N.Y.S.2d 620; People v. Navarro, 134 A.D.2d 460, 521 N.Y.S.2d 82; Matter of Jose R., 49 A.D.2d 869,376 N.Y.S.2d 906).
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