Haselhuhn v. State

BROWN, Justice,

dissenting, in which URBIGKIT, Justice, joins.

Once a member of this court takes a position, nothing short of direction from on high, accompanied by a flash of light and a clap of thunder would cause him to reconsider. I say this because the majority resolutely holds on to a discredited rule of law which it announced in Chapman v. State, Wyo., 638 P.2d 1280 (1982), despite weak, if any, support for that position. According to the majority here, this court adopted a rule in Chapman that “hypnosis raises an issue of credibility with respect to the testimony of a witness, but the fact that the witness has been hypnotized does not render the witness incompetent to testify.”

*288In this case two eyewitnesses to the robbery were hypnotized in order to enhance their memories. The hypnotist was a maintenance man at Pacific Power and Light Company. Witness Barney admitted he was initially unable to positively identify appellant as one of the robbers. It was only after having been hypnotized that he was able to positively identify appellant as one of the robbers.

Courts that have addressed the hypnotically enhanced testimony problem have employed three different approaches. One group admits all posthypnotic testimony by holding that pretrial hypnosis affects only the credibility of a witness rather than his or her competency to testify. The second approach admits .hypnotically enhanced testimony if procedural safeguards are followed. The third category adopts a rule of per se inadmissibility, allowing the witness to testify only to matters recalled before hypnosis.

Wyoming falls into the first group, that is, hypnosis affects credibility but not admissibility. Chapman v. State, supra. It is not clear whether the rule followed by Wyoming was ever a majority rule. It is clear, however, that it is not the majority rule today.

Courts in eleven jurisdictions follow the rule that pretrial hypnosis affects only the credibility of such testimony rather than its admissibility. Twenty-eight jurisdictions have rejected the admissibility of hypnotically enhanced testimony or have restricted its admissibility through the application of procedural safeguards or balancing tests. Trial by Trance: The Admissibility of Hypnotically Enhanced Testimony, 20 Colum.J.L. & Soc.Probs. 237 (1986).

In developing the Chapman rule this court cited Harding v. State, 5 Md.App. 230, 246 A.2d 302 (1968), cert. denied 395 U.S. 949, 89 S.Ct. 2030, 23 L.Ed.2d 468 (1969), as its primary authority. Since Chapman, however, Harding has been overruled. Collins v. State, 52 Md.App. 186, 447 A.2d 1272 (1982). As additional support for its determination in Chapman the majority also relied on cases from Florida, Georgia and North Carolina as authority. The cases relied upon from these states have also been overruled. Bundy v. State, Fla., 471 So.2d 9 (1985); Walraven v. State, 255 Ga. 276, 336 S.E.2d 798, (1985); State v. Peoples, 311 N.C. 515, 319 S.E.2d 177 (1984).

When the authority upon which a rule of law is based becomes seriously eroded, the court adopting the repudiated rule should reexamine its position. Not so in this court. In my specially concurring opinion in Pote v. State, Wyo., 695 P.2d 617 (1985), citing cases, I noted that Chapman represents a rapidly shrinking minority view; it continues to shrink. See Contreras v. State, Alaska, 718 P.2d 129 (1986); State v. Moreno, Hawaii, 709 P.2d 103 (1985); State v. Haislip, 237 Kan. 461, 701 P.2d 909 (1985); People v. Nixon, 421 Mich. 79, 364 N.W.2d 593 (1985). Furthermore, I have not found any recent case which adopts the Chapman rule, nor does the majority cite any. I conclude, therefore, that there are none.

As previously noted, the cases upon which the Chapman majority based its decision have been generally overruled. This court was then left with citing Chapman in support of its decision in Gee v. State, Wyo., 662 P.2d 103 (1983), and citing Chapman and Gee in support of its decision here. This court is now basing decisions on previous errors because that is about all there is left.

Legal treatises, generally, condemn the rule that “hypnosis affects credibility but not admissibility.” Some treatises suggest safeguards. Casenote, Look into My Eyes: The Admissibility of Hypnotically-Enhanced Testimony, 19 Creighton L.Rev. 995 (1985-1986); Trial by Trance: The Admissibility of Hypnotically Enhanced Testimony, 20 Colum.J.L. & Soc.Probs. 237 (1986); Mesmerizing Justice: The Use of Hypnotically-Induced Testimony in Criminal Trials, 34 Syracuse L.Rev. 927 (1983); Note, People v. Zamarripa: To Hypnotize or Not to Hypnotize, 13 Western State U.L.Rev. 651 (1986); Note, Hypnotically Refreshed Testimony and the *289Balancing Pendulum, 4 U.Ill.L.Rev. 921 (1985); Case Comment, Criminal Law-Admissibility of Evidence-Testimony Refreshed by Hypnosis Fails to Satisfy General Acceptance in Scientific Community Standard, People v. Hughes, 8 Thur.Mar.L.Rev. 451 (1983); Case Comment, A New Standard for Admissibility of Hypnotically Refreshed Testimony, 63 Wash.U.L.Q. 325 (1985); Comment, Hypnosis of the Accused: Defendant’s Choice, 75 J.Cr.Law & Criminology 995 (1984).

Hypnosis is an investigative or therapeutic tool, and its credibility is suspect as an evidentiary tool. Cases from other jurisdictions and scholarly treatises are contrary to the rule of law as set forth in Chapman and Gee. Furthermore, most scientists in the medical or psychology fields insist that hypnosis is not reliable, and therefore has no place in the courtroom. See 19 Creighton L.Rev. 995, supra. The court should abandon the rule in Chapman.