Rock v. Arkansas, 483 U.S. 44 (1987) addressed whether a state's evidentiary rule which prohibited the admission of hypnotically refreshed testimony violated a defendant's constitutional right to testify on her own behalf. See id. at 45. The Court determined that a criminal defendant has the right to take the stand and testify on his or her behalf. See id. at 49. It also noted: "On numerous occasions the Court has proceeded on the premise that the right to testify on one's own behalf in defense to a criminal charge is a fundamental constitutional right." Id. at 53 n.10 . The United States Supreme Court granted certiorari "to consider the constitutionality of Arkansas' per se rule excluding a criminal defendant's hypnotically refreshed testimony." The Supreme Court explained that "at this point in the development of our adversary system, it cannot be doubted that a defendant in a criminal case has the right to take the witness stand and to testify in his or her own defense." Id. The Court then determined that a per se rule excluding all hypnotically refreshed testimony was an impermissible infringement upon a criminal defendant's right to testify on his or her own behalf. The issue of how the right to testify may be waived was neither presented to nor decided by the Court.