Maryland v. Craig
Maryland v. Craig is a significant Supreme Court case that addressed the balance between a defendant's right to confront witnesses and the need to protect vulnerable witnesses, particularly children, from potential emotional distress during trials. The case emerged when Sandra Craig was convicted of child abuse, and her trial included the televised testimony of a young child, which Craig argued infringed upon her constitutional rights under the Sixth Amendment. The Supreme Court, in a close 5-4 decision, held that the confrontation clause does not provide an absolute right to face-to-face meetings with witnesses. Justice Sandra Day O'Connor, writing for the majority, emphasized that the reliability of evidence is paramount, allowing for exceptions in cases where a child's psychological well-being is at stake.
The ruling acknowledged that while defendants have rights, the state's interest in safeguarding a child's mental health can outweigh those rights in certain circumstances. This decision raised important questions about the treatment of child witnesses in the legal system and set a precedent for how such cases might be handled in the future. The dissenting opinion by Justice Antonin Scalia expressed concern over the implications of this ruling, stressing the necessity of adhering to the explicit protections provided by the Sixth Amendment. Maryland v. Craig ultimately highlighted the ongoing debate about the intersection of legal rights and the welfare of vulnerable witnesses in court proceedings.
Maryland v. Craig
Date: June 27, 1990
Citation: 497 U.S. 836
Issue: Confrontation of witnesses
Significance: The Supreme Court upheld a criminal conviction based on a six-year-old child’s testimony that was displayed in the courtroom by a one-way closed-circuit television rather than given in person.
A Maryland law specified that a judge might allow the testimony of a young child to be televised if the judge determined that the child’s appearance in the courtroom would result in serious emotional distress, preventing the child from reasonably responding to questions. After Sandra Craig was found guilty of child abuse in a trial using this procedure, she asserted that her conviction was unconstitutional because she had not had an opportunity to confront her accuser.
Speaking for a 5-4 majority, Justice Sandra Day O’Connor argued that the Sixth Amendment did not guarantee criminal defendants an absolute right to face-to-face meetings with witnesses at trial. Rather, the main purpose of the confrontation clause was to ensure the reliability of evidence by rigorously testing it in an adversary proceeding. In some instances, moreover, she concluded, the state’s interest in the psychological well-being of a child outweighs a defendant’s right to confront witnesses in court. Stating that exceptions to face-to-face confrontations must be “case specific,” she remanded the case to the lower courts for further proceedings. In a strong dissent, Justice Antonin Scalia scolded the majority for ignoring an explicit guarantee of the Sixth Amendment.
The Craig decision left many questions unanswered about the use of children’s testimony. In a companion case, Idaho v. Wright (1990), the Court found that hearsay evidence (a physician’s account of his interview with allegedly abused children) must be excluded unless such evidence can be shown to be trustworthy. In White v. Illinois (1992), nevertheless, the Court held that the confrontation clause did not prohibit the admission of testimony recalling a child’s “spontaneous declaration” made to police and doctors.