United States v. Scheffer - 523 U.S. 303, 118 S. Ct. 1261 (1998)

Rule:

A defendant's right to present relevant evidence is not unlimited, but rather is subject to reasonable restrictions. A defendant's interest in presenting such evidence may thus bow to accommodate other legitimate interests in the criminal trial process. As a result, state and federal rulemakers have broad latitude under the Constitution to establish rules excluding evidence from criminal trials. Such rules do not abridge an accused's right to present a defense so long as they are not "arbitrary" or "disproportionate to the purposes they are designed to serve." Moreover, the Court has found the exclusion of evidence to be unconstitutionally arbitrary or disproportionate only where it has infringed upon a weighty interest of the accused.

Facts:

A United States Air Force airman who, as a voluntary informant on Air Force drug investigations, had submitted to a urinalysis and a polygraph test, was tried by a general court-martial on a number of charges, which included using methamphetamine, after the airman was absent without leave and Air Force agents learned that the urinalysis had revealed the presence of methamphetamine. The airman entered a motion to introduce, in support of his testimony that he had not knowingly used drugs, polygraph evidence, where in the opinion of the examiner who had administered the airman's polygraph test, the test had indicated no deception when the airman had denied using drugs. A military judge, relying on Military Rule of Evidence 707--which made inadmissible in court-martial proceedings the results of a polygraph test, the opinion of a polygraph examiner, or any reference to an offer to take, failure to take, of taking of a polygraph test--denied the motion. After the airman was convicted on all charges, the Air Force Court of Criminal Appeals affirmed in all material respects. The United States Court of Appeals for the Armed Forces, reversing, expressed the view that a per se exclusion of polygraph evidence offered by an accused to rebut an attack on the accused's credibility violated the accused's right, under the Federal Constitution's Sixth Amendment, to present a defense. The Government was granted certiorari.

Issue:

Did the exclusion of polygraph evidence violate the accused’s Sixth Amendment right?

Answer:

No.

Conclusion:

The Court found the exclusion of evidence to be unconstitutionally arbitrary or disproportionate only where it has infringed upon a weighty interest of the accused and that Rule 707 served several legitimate interests in the criminal trial process. The rule was neither arbitrary nor disproportionate in promoting these ends. Nor did it implicate a sufficiently weighty interest of the airman to raise a constitutional concern under the Court's precedents, and there was no consensus among jurisdictions that polygraph evidence was reliable. Further, the Court concluded that polygraph evidence could diminish the jury's role in making credibility determinations.