Idaho v. Wright (1989)

Docket
89-260
Decided
1989-01-01

Summary

Question: Does the admission at trial of hearsay testimony made by a child to an examining pediatrician violate the Confrontation Clause of the Sixth Amendment? Conclusion: Yes. Justice Sandra Day O’Connor delivered the opinion of the 5-4 majority. The Supreme Court held that the state bears the burden of showing that the testimony of a witness who is unavailable for trial is sufficiently reliable to withstand scrutiny under the Confrontation Clause. Testimony is deemed reliable when it otherwise falls within a hearsay exception or shows “particularized guarantees of trustworthiness.” In order to meet this high standard of trustworthiness, testimony must be so reliable that adversarial testing under cross-examination would not alter its credibility. Corroborating evidence is not enough to establish the trustworthiness of testimony; it must be inherently reliable. Because the state could neither show that the testimony fit within a hearsay exception nor could they prove that it was inherently trustworthy, it was unreliable and therefore inadmissible under the Confrontation Clause. Justice Anthony M. Kennedy wrote a dissenting opinion in which he argued that the majority’s opinion erred in establishing a rule that corroborating evidence is not sufficient to establish the trustworthiness of testimony. Because corroborating evidence is often the most commonly used and effective ways of determining the reliability of testimony, there is no reason for the majority to remove it as a method of determining whether testimony is sufficiently trustworthy to be admissible under the Confrontation Clause. Justice William H. Rehnquist, Justice Byron R. White, and Justice Harry A. Blackmun joined in the dissent.

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