Evidence; Constitutional Criminal Procedure

United States v. Scheffer — Study Notes

523 U.S. 303 (1998), Supreme Court of the United States

Study notes for United States v. Scheffer: professor notes, cold call prep, exam angles, and memory aids.

The Supreme Court upheld the exclusion of polygraph evidence in military court under M.R.E. 707 as constitutional, ensuring the integrity of military judicial proceedings.
Professor Notes

In United States v. Scheffer, the Supreme Court addressed the tension between evidentiary rules and a defendant's right to present a defense. The Court emphasized the importance of maintaining the integrity of military judicial proceedings, which is why they upheld the categorical exclusion of polygraph evidence under M.R.E. 707. Professors often highlight the implications of this case on both military and civilian contexts, noting how the ruling illustrates the balance courts must strike between a defendant's rights and the credibility and reliability of certain types of evidence.

Additionally, the Court's decision reflects broader themes in criminal procedure, specifically the Sixth Amendment's Confrontation Clause and the rights it guarantees to defendants. It raises critical questions about the nature of admissible evidence, especially concerning its scientific reliability and the role of juries in weighing disputed evidence. This case also serves as a pivotal reference for understanding the limits of constitutional protections in military law versus civilian law.

Cold Call Prep
  1. 1M.R.E. 707 is a rule that excludes polygraph evidence. What are the implications of this exclusion?
  2. 2Explain why the Supreme Court upheld the exclusion of polygraph evidence in this case.
  3. 3How does this case relate to the defendant's Sixth Amendment rights?
  4. 4Discuss potential criticisms of the Supreme Court's ruling in this case.
  5. 5What rationale did the Court provide for prioritizing military judicial integrity?
  6. 6How might a similar case be viewed differently in civilian courts?
  7. 7Can you think of examples of evidence types that courts might exclude for similar reasons?
Mnemonic Device

S-C-H-E-F-F-E-R: Scheffer upheld the exclusion of polygraph evidence for military fairness.

Distinguish From
CaseDistinction
Rock v. ArkansasRock v. Arkansas allowed the admission of hypnotically refreshed testimony, contrasting with Scheffer's categorical exclusion of polygraph evidence based on reliability concerns.
Kumho Tire Co. v. CarmichaelKumho Tire addressed the admissibility of expert testimony, while Scheffer specifically focused on the constitutional implications of evidentiary rules, particularly in military courts.
Policy Arguments

For the Rule

Maintaining a ban on polygraph evidence preserves the credibility and integrity of military judicial proceedings, ensuring they remain reliable and trustworthy.

Against the Rule

Excluding polygraph evidence may infringe on defendants' rights to present a full defense, potentially leading to unjust outcomes in courts-martial.

Class Discussion Points
  • What are the implications of categorical exclusions of evidence in different judicial systems?
  • How does the reliability of evidence impact a defendant's right to present a defense?
  • In what ways might this ruling influence future military and civilian cases regarding evidentiary rules?
Exam Angle

This case may be examined in terms of the balance between evidentiary rules and defendants' rights, particularly regarding the Sixth Amendment. Students should be prepared to discuss the precedential impact of the ruling on both military and civilian law contexts.

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