Evidential Weight of Experienced Police Officers Statement About Field Test for Drugs
The court in People v. Bratton (166 Misc 2d 893, 896 [Crim Ct, NY County 1995]) concluded:
"While a statement by someone with general training and experience in recognizing drugs may provide reasonable grounds to believe that the substance recovered is a specific drug, an expert opinion, by analysis, is required for a prima facie case."
However, Bratton based this conclusion upon its belief that People v. Swamp (84 NY2d 725  had held a "recognized field test analysis" to be "necessary" to establish the alleged contraband to in fact be a controlled substance.
In fact, while Swamp found a field test analysis together with nonhearsay observations by an experienced officer to be sufficient, it nowhere determined that the field test analysis was "necessary," and that the nonhearsay observations by the officer alone would, without such an analysis, be insufficient.
To the contrary, the court in Bratton itself specifically determined that "a statement by someone with general training and experience in recognizing drugs may provide reasonable grounds to believe that the substance recovered is a specific drug" (166 Misc 2d, at 896).