Introduction

In the landmark case United States v. Edward G. Scheffer (523 U.S. 303, 1998), the United States Supreme Court addressed the admissibility of polygraph evidence in military court-martial proceedings. Edward G. Scheffer, an Air Force airman stationed at March Air Force Base, was accused of using methamphetamine. Despite passing a polygraph test indicating "no deception" regarding drug use, urinalysis later revealed methamphetamine in his system. Scheffer sought to introduce the polygraph results to support his defense of innocent ingestion. The military trial court denied the admission of the polygraph evidence based on Military Rule of Evidence 707, leading to his conviction. The primary legal question was whether Rule 707's exclusion of polygraph evidence infringed upon the Sixth Amendment right to present a defense.

Summary of the Judgment

The United States Supreme Court reversed the decision of the Court of Appeals for the Armed Forces, holding that Military Rule of Evidence 707 does not violate the Sixth Amendment rights of the accused to present a defense. Justice Thomas delivered the majority opinion, emphasizing that the exclusion of polygraph evidence is neither arbitrary nor disproportionate to the legitimate interests it serves. The Court concluded that the military's rule effectively ensures the reliability of evidence, preserves the court's role in credibility assessments, and avoids unnecessary collateral litigation. While dissenting opinions highlighted the importance of the right to present a complete defense, the majority maintained that Rule 707 upholds constitutional standards within military justice.

Analysis

Precedents Cited

The Court referenced several key precedents to support its decision:

• ROCK v. ARKANSAS (483 U.S. 44, 1987): This case dealt with the exclusion of hypnotically refreshed testimony and emphasized that evidence exclusion is unconstitutional only when it undermines a weighty interest of the accused.
• WASHINGTON v. TEXAS (388 U.S. 14, 1967): It affirmed the right of a defendant to present witnesses in their defense, ruling against rules that categorically exclude certain testimonies.
• CHAMBERS v. MISSISSIPPI (410 U.S. 284, 1973): This case addressed the combined application of rules that prejudiced the defendant's ability to present a defense, reinforcing that evidentiary exclusions must not be mechanistic in nature.
• DAUBERT v. MERRELL DOW PHARMACEUTICALS, INC. (509 U.S. 579, 1993): Established the standard for admitting expert scientific testimony, focusing on relevance and reliability rather than general acceptance.
• TAYLOR v. ILLINOIS (484 U.S. 400, 1988): Emphasized that the defendant's right to present evidence is subject to reasonable restrictions.

Legal Reasoning

The Court reasoned that the military has broad latitude to set evidentiary rules that are not arbitrary or disproportionate. Rule 707 serves multiple legitimate interests:

1. Ensuring Reliability: The scientific community remains divided on the reliability of polygraph tests, making a per se exclusion a rational method to prevent potentially unreliable evidence from influencing the court.
2. Preserving Credibility Determinations: Polygraph evidence could unduly sway the court's credibility assessments, undermining the role of the fact-finders to independently evaluate witness testimony.
3. Avoiding Collateral Litigation: Allowing polygraph evidence would lead to protracted debates over the validity and administration of such tests, detracting from the primary objective of determining guilt or innocence.

The Court concluded that these interests justify the categorical exclusion of polygraph evidence in military trials, as Rule 707 does not significantly impair the accused's ability to present a defense.

Impact

This judgment solidifies the authority of military judicial systems to exclude certain types of evidence deemed unreliable without infringing on constitutional rights. It underscores the deference courts grant to rule-makers within the military framework, particularly concerning evidentiary standards. Future cases involving the admissibility of scientific or expert testimony in military settings will reference this decision to uphold or challenge existing evidentiary rules. Additionally, the ruling delineates boundaries between military and civilian judicial processes regarding evidence admissibility, potentially influencing discussions on similar exclusions in other federal or state courts.

Complex Concepts Simplified

Per Se Exclusion

A per se exclusion is a rule that prohibits the admission of certain evidence outright, without considering the specific circumstances of a case. In this context, it means that any polygraph evidence is automatically excluded from being presented in military court-martial proceedings.

Credibility Determinations

Credibility determinations refer to the process by which a court assesses the trustworthiness of a witness's testimony. The exclusion of polygraph evidence aims to prevent external factors from unduly influencing this assessment.

Military Rule of Evidence 707

Military Rule of Evidence 707 specifically bars the admission of polygraph results, the examiner's opinion, or any reference to taking a polygraph test in court-martial proceedings.

Conclusion

The Supreme Court's decision in United States v. Edward G. Scheffer reaffirms the constitutionality of Military Rule of Evidence 707, which excludes polygraph evidence from military court-martial trials. By upholding this rule, the Court balances the defendant's right to present a defense with the military's legitimate interests in ensuring evidence reliability, preserving the integrity of credibility assessments, and maintaining efficient judicial proceedings. This ruling maintains the exclusion of polygraph evidence in military trials and sets a precedent for similar evidentiary considerations, emphasizing the deference courts owe to established military rules within the framework of constitutional protections.