What is the test for a defense expert's testimony on the effect of stress on eyewitness identification?

of the trial court (People v. Lee, 96 N.Y.2d 157, 160, 726 N.Y.S.2d 361, 750 N.E.2d 63 [2001] ). Such decision should be guided by whether the proffered expert testimony would aid a lay jury in reaching a verdict (id. at 162, 726 N.Y.S.2d 361, 750 N.E.2d 63 [internal quotation marks omitted] ). We have acknowledged, however, that

Under the circumstances of this case, it cannot be said that the trial court abused its discretion in not allowing the defense expert to testify with regard to the effect of stress on the reliability of eyewitness identification. The People sought a ruling at trial concerning the parameters of the defense expert's testimony. The defense failed to submit any evidence demonstrating that its expert's testimony on the topic of event stress met the reliability concerns of Frye v. United States, 293 F. 1013 (D.C.Cir.1923).

In any event, the trial court did not wholly preclude the defense expert from

[49 N.E.3d 710]

[29 N.Y.S.3d 241]