Confrontation Clause Revisited: Supreme Court Decisions Idaho v Wright, and Craig v Maryland -
A Psychologist's Response
These two Supreme Court decisions relating to questions
of constitutional constraints and requirements for the justice system in
handling allegations of child sexual abuse demonstrate the great
difficulties in the relationship between the legal system and the
science of psychology. The Maryland v. Craig decision
particularly sets up a requirement that no reasonable nor responsible
mental health professional should even begin to attempt to meet. The
impact of this ruling and the contretemps it will create for
psychologists must be discussed.
The Syllabus summarizes the requirement "(c) The
requisite necessity finding must be case specific. The trial court must
hear evidence and determine whether the procedure's use is necessary to
protect the particular child witness's welfare; find that the child
would be traumatized, not by the courtroom generally, but by the
defendant's presence; and find that the emotional distress suffered by
the child in the defendant's presence is more than de minimis."
This ruling appears to demand that
there be an evidentiary hearing, prior to the trial, at which
there will be testimony, most likely by experts, about the effect on the
specific child of testifying in the presence of the
person accused. A judge may, of course, question a child but it is a
rare judge who will say "I alone can determine the questions
raised by the Supreme Court's rulings." If
the judge decides the child will, indeed, be so harmed by the appearance
of the defendant in the presence of the child, then the judge may order
the use of a videotape process so that the child testifies but is not
able to see the defendant. However, the prosecution apparently must elect
to try to get videotaped testimony before the fact finder rather than
place the child on the stand to testify in the presence of the
defendant. Then there will be the hearing on this issue.
The experts, therefore, who will be asked to offer
opinions on this question are most likely psychiatrists, psychologists, and social workers, the professionals
currently offer expert opinions in child sexual abuse cases. While some
law enforcement professionals may now give expert opinions in sexual
abuse cases, it is highly unlikely that a court would qualify law
enforcement officials to give an opinion on the future effects of
testifying on a young child. Psychologists supposedly are the more
reliable diagnosticians and assessors in the mental
health team. It is both psychologists and psychological research that is
going to be used in trying to meet this requirement.
The simple fact is that psychologists cannot do it. No mental health professional can respond to this
with anything other than speculative, unfounded and unsupported,
There is no research that approaches being able to
separate out the single factor of the defendant's presence
from all other factors that may produce more than minimal emotional
distress. It is questionable whether there is any body of psychological
research dealing with causation of human behavior that can claim to have
isolated a unidimensional causal factor. In spite of decades of effort,
we still have no data to tell us whether intelligence is a single
general factor or a multidimensional capacity. Nobody knows how to
isolate or identify the specific factor of the presence of the
defendant, by itself, causing serious emotional distress.
The Supreme Court's ruling also requires
psychologists to make a prediction that the presence of the defendant
alone will cause serious emotional harm. The ruling clearly states that
this must be "more than mere nervousness or excitement or some
reluctance to testify." How can this prediction be made?
of data is necessary to present in a court of law the prognosis of
severe emotional trauma to a child? The attempt to establish the
etiology, nature, treatment, and prognosis of childhood disorders
continues to leave most of the major questions unanswered. The most that
can be claimed on the basis of empirical data is that there are two
broad-band syndromes, "undercontrolled" and "overcontrolled"
behavior. The narrow-band syndromes of hyperactivity, aggression, and
delinquent behavior form the "undercontrolled" syndrome.
Anxiety, depression, somatic complaints and obsessive-compulsive
behavior covary to form "overcontrolled" behavior (Ross &
Pelham, 1981; Achenbach & Edelbrook, 1984). Where in
this limited area of child psychopathology concepts is there anything
permitting the prediction of serious emotional trauma as required
by the Supreme Court?
It is also likely to be the case that the effort to
protect children from harmful effects of testifying will focus
primarily on younger children. It seems reasonable to expect prosecutors
to conclude that the older the child the less need there is for
protection, although again there is no scientific data to permit a
psychologist either to give that advice or express that opinion. There
are two problems psychologists must consider in response
to the Supreme Court's expectation and requirement. The first is simply
the issue of predicting anything given the current state of our science.
The second is the ability of psychology to measure or to assess the
level of trauma in young children with any validity or reliability.
No psychologist can deny that we are not very good at
prediction. In order to arrive at any prediction, it is necessary to
meet two prerequisites. There must be a sound and empirically-supported
theory about the causal variables involved in whatever phenomenon
we are interested in predicting. Secondly, we must have an adequate and
reliable method for measuring those variables (Meehl,
1973). We are nowhere near meeting those requirements in relationship to
the Supreme Court's ruling that a case specific finding must be
made on the effects of testifying caused by the presence of the
For most of the contexts in which prediction has been
studied, predictability is low for both clinical and actuarial methods (Dawes, 1990a).
Nevertheless, statistical prediction has been shown to
be more accurate and more valid than clinical prediction.
There is no controversy in social science that shows
such a large body of qualitatively diverse studies coming out so
uniformly in the same direction as this one (the relative value of actuarial
versus clinical prediction). When you are pushing 90
investigations, predicting everything from outcomes of football games to
the diagnosis of liver disease and when you can
hardly come up with a half dozen studies showing even a
weak tendency in favor of the clinician, it is time to draw a practical
conclusion (Meehl, 1986, p. 370).
The practical conclusion is that psychologists had
better keep their mouths shut about clinical impressions, clinical
observations, and clinical interviews. Given the current status of the
research evidence, any psychologist who bases an opinion, a diagnosis,
or a decision on clinical data alone is vulnerable to serious challenge,
possible embarrassment, and a potential for charges of unethical behavior.
psychologists, as well as psychiatrists and social workers, are not
likely to accept the reality that a simple linear model does better than
their years of training, their highly intelligent, sophisticated,
richly experienced observations and cognitions and their powerful
intuitions (Dawes, 1988).
But simple linear models outperform experts in every
study (Dawes 1990). If clinicians attempt to inject some form of
subjective judgment or fiddle with weighting factors the only effect is
to reduce the accuracy of the simple actuarial procedure (Dawes, 1988,
1990). If psychologists did the honest thing and told the justice system
a jury or judge can do better with a $2.95 hand
calculator than by attending to the pontification of experts, the
cherished beliefs about mental health experts' ability to see inside
other people and understand them better than they do themselves would
have to be abandoned. In spite of the highly reinforcing cocktail party
experience of frequently being asked for counsel, advice,
or being feared as a soothsayer, psychologists most forthrightly should
make clear the limitations and the qualifications of their wisdom and competence.
The second issue of assessing the future trauma to young
children must also be considered realistically in light of the best
scientific information available on the ability of mental health
professionals to make valid and reliable assessments of young children.
A basic principle is that adult criteria of psychopathology cannot be
applied to children (Bemporad & Schwab, 1986). Achenbach (1980)
observes that most adult disorders have no clear counterpart in children
and adult-oriented diagnostic constructs cannot be indiscriminately
transferred to children. Children must be assessed in terms of their
need for return to and continued normal development. The number of
mental health professionals who may be qualified by the court as experts
and both understand and are guided by this reality is likely to
be very small. Therefore opinions expressed on the possible serious
emotional trauma caused by testifying in the presence of the defendant
are apt to be influenced by imposition of constructs of adult
psychopathology on children. This is what the Supreme Court does when it
requires that a child must exceed mere nervousness, excitement, or a
reluctance to testify. These are adult concepts applicable to adults but
there is no basis for an uncritical and unreflective transfer to young
Meeting the Supreme Court requirement demands a
taxonomic category that must demonstrate acceptable validity and
reliability. The DSM-III and III-R represent the best effort thus far to
produce taxonomies for childhood and adolescence disturbance. There has been severe and continued criticism of the DSM-III
childhood and adolescence section. The major issue is the extent to
which DSM-III meets accepted criteria for a good classification system
for behavior. Quay (1986) summarizes multivariate
analytic studies bearing on this section and concludes "... it is
clear that DSM-III has far more categories than have been empirically
validated" (p.158). He states "There is very, very little
evidence from the multivariate literature that supports separate and
distinct syndromes of anxiety and depression in children" (p.154).
Yet these are the very behaviors which are most likely to be predicted
as showing a young child cannot testify in the presence of a defendant.
In examining the research on reliability Quay (1986) reports an overall
kappa for the major category of Anxiety Disorders in children of .52.
Chance level is .50. Note that this reliability estimate is for the yes
or no classification of Anxiety Disorder, not the subtypes. He concludes
"The major category of Anxiety Disorders is below the rather
minimal level of .60 for the Conduct Disorders" (p.
161). If the best effort of the mental health professions to produce
categories that are useful and meaningful for describing
and predicting childhood and adolescent behaviors cannot demonstrate
anything better than chance, how can any psychologist go into a court of
law and give an opinion predicting a young child's response to
testifying in the presence of the defendant? The data show that a
would likely do just as well by flipping a coin and saving a great deal
of time and expense.
Assessment requires some form of measurement. For
psychologists, this comes down to psychometric procedures
showing sufficient reliability and validity to be used as psychological
tests. For young children there are very few procedures that have
demonstrated acceptable levels of validity and reliability. McReynolds
(1989) reviews tools for clinical assessment and presents three tests
for children with supportive research showing acceptable levels
of validity and reliability. They are the Child Behavior Checklist
and Profile (Achenbach & Edelbrook, 1983); the Personality
Inventory for Children (Wirt, Lachar, Klinedinst, & Seat, 1984); and the
Brief Psychiatric Rating Scale for
Children (Gale, Pfefferbaum, Suhr, & Overall, 1986). None of
these procedures provide information useful for predicting a child's
response to testifying.
One of the more astonishing facts about psychology
and children is that psychologists continue to use procedures for which
there is no demonstrated validity or reliability. These unsupported
procedures include drawings, projective tests, clinical interviews, and
dolls (Wakefield & Underwager; 1988, Underwager & Wakefield,
1989). Melton (1989), in reviewing the Child Abuse Potential
Inventory, a device he
regards as psychometrically acceptable, makes a statement that is
applicable to the widespread use of unacceptable procedures as well.
First, although the qualifications in the manual are
well specified, my experience in conducting continuing education workshops
leaves me virtually certain that such qualifications about the
application of base rates will seldom he provided in practice, and, if
provided, rarely understood or heeded (p. 154).
There is little basis to think that psychologists who
use procedures that are completely devoid of any demonstrated
acceptability will either understand their mistaken and
unethical behavior or change it. "What has happened is that
the public is awed, and — worse yet — many practitioners pay little or no
attention to the reviews. (If they did, none would have
given a draw-a-person test or a Rorschach Ink Blot test since the
early 1970s)" (Dawes, 1990b). Nevertheless, when psychologists
use such unacceptable procedures in an attempt to meet the
Supreme Court's requirement, any prediction including
information alleged to be based on these procedures can be
objected to or clearly impeached.
Can experience enable a psychologist to meet the
Supreme Court requirement for case-specific prediction on the effects of
testifying? An American Psychological Association (1982) Task Force
concluded there was no evidence that professional competence is in any
way related to years of experience as a psychologist. Garb (1989)
reviewed the research on clinical experience and accuracy of judgments
and decisions. There is no relationship to accuracy. There is no
relationship of accuracy to expressed confidence in judgments or
decision. The only effect experience has comes from mastering techniques
that demonstrate acceptable validity and reliability. There is no
increment from experience with a technique beyond that of the validity
of the technique itself when it is properly used. "The results
on validity generally fail to support the value of experience in
mental health fields. However, the results do provide limited support
for the value of training" (p. 391). There is no evidence that an
experienced clinician can somehow overcome the weaknesses of invalid and
unreliable techniques and do a better job than the shoddy technique.
In describing his experience on the American
Psychological Association Ethics Committee Dawes (1989) states that the
most common complaint against psychologists who gave testimony was that
a diagnostic or predictive conclusion had been reached without having
interviewed the person. There was one practice about which there were no
complaints, that is the claim that experience alone qualifies a person to express
That was the assertion that the testifying clinical
psychologist was qualified to make diagnostic or
predictive judgments with "reasonable certainty" on the basis
of "experience" with people similar to
the person about whom the judgment was made. If, of course, such
experience (e.g., "30 years of dealing
with abusive parents in my private
practice") was unrelated to the validity of the judgment made, then
citing it as justification would constitute incompetence, and according
to the rules of the American Psychological Association, incompetence is
unethical (Ethical Principles of Psychologists, Principle 8e, 1981).
Moreover if the research evidence indicates that experience is not a
valid ground for claiming expertise, the psychologist is ethically
mandated to be aware of that research and to act in accord with its
findings (Ethical Principles of Psychologists, Principle 8e,
1981) (Dawes, 1989, p. 458).
Given all these considerations, a psychologist cannot
in good conscience and as a responsible professional go into a court of
law and give testimony that a child will be so seriously damaged
by the sole factor of the presence of the defendant that the use of a
videotaped testimony procedure is mandated. Any psychologist who does
offer such testimony is behaving in an unethical manner. A psychiatrist or social worker who may elect to offer such an opinion
demonstrates the weakness of psychiatric and social work training and is
subject to rational and irrefutable impeachment.
For the psychologist not only is the ethical
principle cited by Dawes involved, but the fundamental ethical
requirement not to harm people or to abridge or deny their individual or
civil rights is involved. When there is an allegation of sexual abuse,
this is an highly charged environment in which the lives of individuals
are markedly and dramatically affected. Children who have been abused
are liable to be missed. Children who have not been abused may be
victimized by adults who teach them to believe they have been abused.
Persons accused may be wrongfully convicted and spend years or a
lifetime in prison. Families that may have been responsive to treatment
may be permanently destroyed. Psychologists must very carefully and
thoughtfully ascertain that any testimony proffered in an
evidentiary hearing prior to a trial to determine if videotaped
testimony of a child is permitted at trial is based upon sound and
credible scientific data that can be provided to the court and to the
public and to peers. If that cannot be done, the psychologist must avoid
giving testimony. If other mental health professionals do offer the
court opinions on this issue, the psychologist must be wiling to offer
evidence showing the impossibility of meeting the requirements of
the Supreme Court Ruling.
The Supreme Court majority ruling in Maryland v.
Craig twice cites the American Psychological Association Amicus
Curiae brief and refers to authorities cited in the APA brief.
Justice O'Connor accepted the claim of the APA Brief that
there is a "growing body of academic literature documenting
the psychological trauma suffered by child abuse victims who must testify
in court." The Amicus Curiae
Underwager, Wakefield, and Kiefer (1990), submitted in response to the
APA brief, asserts that low and doubtful validity material is presented
to the Supreme Court by the APA brief as if it were high and clear validity
material. The APA brief's claim that there is now strong scientific
evidence relating to effects of testifying is highly questionable.
citation of material boils down to a single study by
Goodman, who is also author of the brief, purporting to show
evidence of trauma. One study does not constitute strong
When a high status professional association of
psychologists claims to speak for the science of psychology
and gives opinions that are questionable and do not represent the
highest standards of the profession to one of the most powerful
institutions in our society, it is not surprising that decisions and
policies then elaborated by that institution may be flawed and
unrealistic. Rather than properly informing the Supreme Court of the
limitations of the application of the science of psychology to vexing and
troublesome social issues, the APA brief encourages and advances
overinflated and overly optimistic concepts of what psychology and psychologists can do.
The choice by Psychology and Law,
Division 41 of the American Psychological Association, to
sponsor and recommend this brief and the decision by the APA
Chief Executive Officer, Raymond Fowler, to submit it to the Supreme
Court as an Amicus Curiae brief of the American Psychological
Association must share the onus of abetting the establishment of a
procedure which psychologists cannot ethically perform.
A further instance of the tension between the justice
system and psychology is the unquestioning acceptance by the law that
physical presence, oath, demeanor of witnesses, and cross-examination can
assure the reliability of evidence presented. The Supreme Court majority
opinion in Maryland v. Craig relies upon these elements of
confrontation and asserts that videotaped testimony preserves and
presents these factors and is therefore acceptable. Face-to-face
confrontation is not necessary for these purportedly effective variables
to be available to the fact finder. Therefore, the goal of the most
accurate and reliable decision may be met through the use of a
When the Supreme Court accepts and relies upon these concepts in Maryland v.
Craig, it is an example of what Meehl (1989) calls "fireside
... I mean those
commonsense empirical generalizations about human behavior which we
accept on the culture's authority plus introspection plus anecdotal
evidence from ordinary life. Roughly the phrase,
"fireside inductions" designates here what everybody (except
perhaps the skeptical social scientist) believes about human
conduct, about how it is to be described,
explained, predicted, and controlled. ... That the psychological
presuppositions underlying the criminal law should
be subjected to merciless
armchair scrutiny and quantitative research is not said pro forma,
expresses a sincere conviction (p. 522-523). ... In thinking about
law as a mode of social control, adopt a healthy skepticism toward the
fireside inductions, subjecting them to test by statistical methods
applied to data collected in the field situation ... (p. 540).
Meehl (1989) also draws a distinction between
psychological theories, techniques, and procedures with high and clear
validity and those with low and doubtful validity. Only those with
high and clear validity
should be used to challenge and hopefully correct "fireside
inductions." Testimony in court by psychologists should be limited
to high and clear validity material or at the very least
the limits and qualifications of low and doubtful validity
statements must be described.
There is a body of scientific research that bears
upon one of the four factors, demeanor. Demeanor is often referred to in
the justice system. The belief is that judges, juries, and attorneys can
discern truthfulness and deception by observing the demeanor of a
witness. A recent review of the available research on deception (Hyman,
1989) concludes "Although I have managed to read only a small
fraction of the literature, I have become optimistic about the
possibility of a coherent psychology of deception in the strong
sense" (p.151). Deception may be deliberate and willful as
in the behavior of a con man. It may also be unwitting and the consequence
of error, stupidity, or dogmatism.
Children practice deception. Triplett (1900) observed frequent deceptions among young children.
& Lassiter (1985) report that young children frequently lie. However, they do not do it very well.
First graders do not fool their
peers but by fifth grade children fool their peers, strangers, and
sometimes their parents. Deception appears to require a minimum set of
cognitive capacities to be effective. There is a developmental process
so that by early adolescence children are reasonably effective in
deceiving others (Hyman, 1989). Some theorists claim there is an
adaptive benefit to being skilled at deception and that it is one of the
factors in the natural selection process (Bond, Kahler, & Paolicelli,
1985; DePaulo, Rosenthal, Green, & Rosenkrantz, 1982).
Human beings are not at all good at detecting
deception. The confidence of the law that demeanor of witnesses can be
successfully read to permit a finder of fact to reliably assess
truthfulness or deception is erroneous. The relevant research shows many
of the false ideas common sense enshrines and maintains. The
common-sense concept that people who look you in the eye are being
truthful while those whose gaze is shifty and indirect are being
deceptive is false. It is liars who look you in the eye (Bond, et al.
There are behavioral cues to deceit but
"observers who are exposed to the usual interpersonal input, the
full audio-visual presentation, ignore these behavioral clues and
instead rely upon those aspects of voice and speech which do not
differentiate deceptive from honest behavior" (Ekman, 1989, p.
79). This study suggests that the Supreme Court's assumption that video-taped
testimony can provide a finder of fact with all the cues of a live
presence is questionable. It may well be that videotaped testimony does
not increase accuracy and reliability of assessment
of evidence by a fact finder but may increase error.
Bull (1989) examines the question of whether training
can increase the ability to detect deception and concludes on the basis
of published studies that on the job experience and training does not
increase ability of law enforcement officers to detect deception. There
are many hazards in the detection of deceit described by Ekman and
O'Sullivan (1989) who also present a 39 item checklist for the
In deadly deceits, when a truthful person could be
falsely imprisoned or executed for a crime or a lying murderer could
escape conviction, every legal attempt should be made to discover
the truth. But the process of interpreting clues to deceit
or truthfulness should be more explicit, more deliberate, and more
careful (Ekman & O'Sullivan, 1989; p. 329).
Research related to deception and the detection of
deception demonstrates across a large number of diverse studies that
there is no basis to assume a better than chance performance by either
trained or untrained persons. There is some suggestion that use of
audiovisual presentation may increase the unreliability of assessments
by observers of the behavior. The "fireside induction" of the
Supreme Court that observation of demeanor through a videotape process
can assure reliable assessment of evidence and this meets the
constitutional requirement for confrontation is not supported by the
empirical research available.
The other side of the situation is the possibility of
a fact finder having a predisposition to see a certain kind of witness
as more accurate or credible than they are. An examination of this
question in the review chapter by Dunning (1989) concludes that "If
the relevant case involves sexual abuse, a child is
likely to be seen as particularly credible" (p. 235). If
there is little evidence to suggest jurors can detect deception and some
evidence to suggest jurors are more likely to find a young child in a
sexual abuse case as particularly credible, a reasonable conclusion is
that child sexual abuse cases may have a disproportionate level of false
positives, wrongful convictions of innocent people.
This is the kind of information that psychology ought
be making available to the justice system rather than presenting low
and doubtful validity material that may result in further extension of
concepts without empirical referents into establishing policies or
An important kind of expert testimony should consist of a scholarly showing
trustworthy expertise exists (either side!)
in certain areas. But because of widespread scientific
incompetence among practitioners, such critical testimony will collide
with the customary legal standard ... If our evidentiary
rules do not permit this critical, consensus challenging role for the
expert ... then the idea of greatly restricting areas of psychological
expertise ... becomes regrettably more appealing (Meehl, 1989, p. 547).
The other factors of the Supreme Court ruling, i.e.,
physical presence, oath, and cross-examination, that are asserted as
aiding in the establishment of accurate and reliable testimony may also
be subject to challenge. Briefly, there is evidence showing that jurors
respond to physical attractiveness and overrate good-looking persons and
judge more harshly ugly persons. Physical presence, therefore, is not
likely to be a clear advantage for reliability. The oath taking is
problematical because young children often are not even asked to take an
oath. The research on cognitive development clearly demonstrates young
children do not have the cognitive capacity to
understand the concept of oath. There is no guarantee that cross
examination can be trusted to assure reliable evidence is presented to
the fact finder. Too many variable factors may affect cross-examination
to diminish any effectiveness to simply accept it as characterized in
the Supreme court ruling "the greatest legal engine ever invented
for the discovery of truth."
But this does not mean that children cannot provide
evidence in a manner to assist a fact finder in reaching a reasoned
decision. Children can be sources of reliable information for adults.
Adults need to know and understand the strengths and weaknesses of
children, the possibilities and limitations imposed by the developmental process, and the impact of their own behavior on
children. The problem is not so much with children but rather with
adults who do not know how to behave so as to permit a child to produce
the most reliable information they can (Garbarino & Stott, 1989).
The account of the three-year-old Colorado girl who was
found in the bottom of an outhouse in a National Forest recreational
area shows that children can give credible and reliable information
(Jones & Krugman, (1986). The difference was that adults knew
nothing about the girl and therefore had no preconceived notions or
hypotheses. They had to be open ended and allow free recall statements
from the child. She was able to provide an account that resulted in the
arrest and conviction of the assailant.
The Supreme Court Ruling in Maryland v. Craig does
not encourage the development of effective means to permit children to
provide the best and most reliable information they are capable of.
Instead, it sets up impossible procedures and goals that cannot be met
by any reasonable person. It can only have the effect of further
complicating and confusing the attempt to reduce the frequency of child
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