U.S. v. Hall

In U.S. v. Hall (7th Cir. 1996) 93 F.3d 1337, the Court of Appeals found the expert's testimony on false confessions should have been admitted, noting as a foundation for its analysis that "each case necessarily turns on its own facts" and that "the jury was entitled 'to hear relevant evidence on the issue of voluntariness.'" Further, that the trial judge would "'instruct the jury to give such weight to the confession as the jury feels it deserves under all the circumstances.'" (Id. at p. 1344.) The court's reasoning continued: "By analogy, it was certainly within the jury's province to assess the truthfulness and accuracy of the confession. . . . The court indicated that it saw no potential usefulness in the expert's evidence, because it was within the jury's knowledge. This ruling overlooked the utility of valid social science. Even though the jury may have had beliefs about the subject, the question is whether those beliefs were correct. Properly conducted social science research often shows that commonly held beliefs are in error. Dr. Ofshe's testimony, assuming its scientific validity, would have let the jury know that a phenomenon known as false confessions exists, how to recognize it, and how to decide whether it fit the facts of the case being tried. The district court's conclusion therefore missed the point of the proffer. It was precisely because juries are unlikely to know that social scientists and psychologists have identified a personality disorder that will cause individuals to make false confessions that the testimony would have assisted the jury in making its decision. It would have been up to the jury, of course, to decide how much weight to attach to Dr. Ofshe's theory, and to decide whether they believed his explanation of Hall's behavior or the more commonplace explanation that the confession was true. But the jury here may have been deprived of critical information it should have had in evaluating Hall's case." (Hall, supra, 93 F.3d at pp. 1344-1345.)