Trammel v. United States case brief

Trammel v. United States case brief summary
445 U.S. 40 (1980)

CASE SYNOPSIS

The Court granted certiorari to review a decision of the United States Court of Appeals for the Tenth Circuit, which affirmed petitioner's conviction on federal drug charges that held the trial court had not erred in admitting the adverse testimony of petitioner's wife because the Hawkins decision did not prohibit the voluntary testimony of a spouse.

CASE FACTS
Petitioner was convicted on federal drug charges and appealed his conviction, arguing that, under the Hawkins rule, which barred the testimony of one spouse against the other, the trial court erred in admitting the adverse testimony of petitioner's wife. The lower court rejected petitioner's claim and affirmed his conviction, and petitioner sought review.

DISCUSSION

• The Court affirmed. 
• The Court noted that the Federal Rules of Evidence acknowledged the authority of the federal courts to continue the evolutionary development of testimonial privileges in criminal trials, and that since its decision in Hawkins, a number of states had abolished the spousal privilege, and the privilege had been subject to much criticism. 
• Therefore, the Court held that it would modify the Hawkins rule so that the witness-spouse alone had a privilege to refuse to testify adversely; the witness could neither be compelled to testify nor foreclosed from testifying. 
• The Court concluded that such a modification would further the important public interest in marital harmony without unduly burdening legitimate law enforcement needs.

CONCLUSION
The Court affirmed the lower court's decision, holding that, although the Hawkins rule could be interpreted to prohibit the voluntary testimony of petitioner's wife without petitioner's consent, the Court was modifying the rule so that the witness-spouse alone had a privilege to refuse to testify adversely; the witness could neither be compelled to testify nor foreclosed from testifying.


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