Each of these Sixth Amendment Court Cases is somehow significant to the way the Supreme Court has interpreted the Confrontation Clause in the Sixth Amendment to the US Constitution. Well, most are significant, some are just interesting! You can read about the history and meaning of the Sixth Amendment here.
Before 1965, the Court had little need to address the scope of the
Confrontation Clause's protections of the rights to cross-examine a
witness and to do so face to face. This was because the Bill of Rights
was originally only a restriction against the Federal government, and
not against the states. Gradually, after the introduction of the 14th
Amendment after the Civil War, through the use of the 14th Amendment's
Due Process Clause, nearly all of the restrictions in the Bill of
Rights have also been applied to the states. You
can read the 14th Amendment here.
The application of the Confrontation Clause through the 14th Amendment did not occur until 1965. Prior to that time, the Court was in charge of the federal court system and regulated the use of the Confrontation Clause's provisions. After that time, with the introduction of a broad mix of state laws into the process, the Court was obliged to clarify to a greater extent, the use and scope of the clause.
Sixth
Amendment Court Cases - Confrontation Clause -
Smith vs. Illinois
Smith vs. Illinois, 1968, addressed the issue of whether or not the
state could introduce as evidence, statements obtained from an
undercover police informant, against a defendant charged with selling
drugs. The state would not produce the witness in person because it
said that revealing his identity would undermine the secretive nature
and strategies used by the police department.
The defendant claimed that his 6th Amendment Confrontation Clause right
to confront the witness had been violated in his trial and that the
conviction should be thrown out. The Court agreed with the defendant. The right to cross-examine a witness is absolute.
Sixth
Amendment Court Cases - Confrontation Clause -
Bruton vs. United States
In Bruton vs. United States, 1968, the issue of whether or not a hearsay
statement could be used as evidence in a trial was addressed. What
makes Bruton unique is that it involves the statement of one person
against another person who were tried in a joint trial, neither of whom
took the stand, taking advantage of their 5th Amendment right not to
have to testify against themselves.
In this case, the two defendants, Bruton and Evans, were charged with
armed postal robbery. During the trial, a postal inspector said that
Evans had confessed to him that both he and Bruton had committed the
crime. Neither Evans nor Bruton took the stand in the trial. When the
jury was deliberating its decision, the judge instructed them that the
hearsay testimony of the postal inspector could not be used as evidence
against Bruton, and they should disregard this statement when making
their decision. He also told them that the statement could be used
against Evans himself.
The principle being addressed here is that Bruton's defense
attorney could not cross-examine the witness, Evans, who allegedly made
the statement, because Evans was not going to take the stand! This
violated Bruton's 6th Amendment Confrontation Clause right to
cross-examine the witness!
The first court found Evans and Bruton guilty. The Supreme Court ruled that the conviction against Bruton had to be thrown out because his Confrontation Clause right to cross-examine the witness had been violated. Later, by the way, the conviction against Evans was thrown as well, based on other violations.
This was an important case because it is a favorite trick of
prosecutors to conduct a joint trial and use witnesses
statements against each other. The statements can't
be used by the jury if the witnesses aren't taking the stand, but the
jury heard them anyway and the statements might influence them even
though they are told to disregard them. Although there are exceptions,
this ruling has eliminated many joint trials.
Sixth
Amendment Court Cases - Confrontation Clause -
Maryland vs. Craig
Maryland vs. Craig, 1990, dealt with the use of closed-circuit
television in a trial. An allegedly abused child was allowed to testify
over closed-circuit television because the prosecutor was able to prove
to the court that additional trauma would occur to the alleged victim
if the victim were to testify in the presence of the defendant. The
proof given to the court followed established procedures and guidelines
of Maryland law.
The Court ruled in this case that the defendant's 6th Amendment
Confrontation Clause right to confront the witnesses against him had
not been violated. The Court said that the extraordinary circumstances
of the case, the fact that the defense counsel was allowed to
cross-examine the witness and the fact that the judge, jury, defendant
and attorneys could see the demeanor of the witness as she testified,
satisfied the requirements of the Confrontation Clause.
Read
more about the history and meaning of the Confrontation Clause
here.
Read
more about the history and meaning of the 6th Amendment here.
Learn more about Sixth Amendment Court Cases relating to the following
Sixth Amendment clauses:
Sixth Amendment Court Cases - Speedy
Trial Clause
Sixth Amendment Court Cases - Public
Trial Clause
Sixth Amendment Court Cases - Right
to Trial by Jury Clause
Sixth Amendment Court Cases - Arraignment
Clause
Sixth Amendment Court Cases - Compulsory
Process Clause
Sixth Amendment Court Cases -
Right to Counsel Clause
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