Idaho v. Wright

Laura Lee Wright (defendant) was married to Robert Giles. Wright had two daughters, one of whom, Kathy, she shared with Giles. When the older child was five and a half years old and Kathy, the younger child, was two and a half years old, the older child stated that Wright helped Giles rape both children. A pediatrician, Dr. John Jambura, examined the children and found evidence of rape. During his examination of Kathy, Dr. Jambura asked whether Giles touched Kathy with his penis. Kathy did not answer. However, Kathy spontaneously told Dr. Jambura that Giles “did it” with Kathy but “did it” far more frequently with the older child. The State of Idaho (the state) (plaintiff) charged Wright with two counts of lewd conduct with a minor—one count related to Kathy, and the other count related to the older child. When the matter went to trial, Kathy was three years old, and the parties agreed that she was not capable of testifying and therefore was unavailable for trial. Dr. Jambura testified about his examination of Kathy and the statements Kathy made. The court found that Kathy’s statements were admissible under Idaho’s residual exception to the hearsay rule. Wright was convicted of the charges and sentenced to 20 years’ imprisonment. Wright appealed the conviction that related to Kathy, arguing that the admission of Kathy’s statements violated Wright’s rights under the Confrontation Clause. The Confrontation Clause required that if a witness was unavailable to testify, the state had the burden of showing that the witness’s hearsay statements bore sufficient indicia of reliability by satisfying one of two factors: (1) the applicable hearsay exception was firmly rooted, meaning that there was sufficient jurisprudence testing the exception’s constitutionality, or (2) the statements carried sufficient guarantees of trustworthiness. The state conceded that it could not show the first factor and argued that it had satisfied the second factor because Kathy’s statements were corroborated by the physical evidence of abuse. The Idaho Supreme Court held that Kathy’s statements lacked sufficient guarantees of trustworthiness and were inadmissible. The Idaho Supreme Court reversed Wright’s conviction and remanded for a new trial. The United States Supreme Court granted certiorari.