Sunday, December 22, 2013

United States v. Scheffer case brief

United States v. Scheffer case brief summary
523 U.S. 303 (1998)

Petitioner Government challenged the decision of the United States Court of Appeals for the Armed Forces, which reversed the lower court's judgment that a polygraph examination of respondent airman was inadmissible under Mil. R. Evid. 707, Manual for Courts-Martial, during his court-martial proceeding.

Airman tested positive for the use of drugs in a urine test administered by Air Force Office of Special Investigations. He was later court-martialed for various offenses and sought to use results from a polygraph examination pertaining to those matters. The military judge denied airman's motion to admit polygraph, he was convicted, and Air Force Court of Criminal Appeals affirmed. The U.S. Court of Appeals for the Armed Forces reversed. Government was granted certiorari.


  • 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.

The Court reversed.

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