Bridges v. State

Rule of Law:

A witness's prior out-of-court statements are admissible as non-hearsay circumstantial evidence if offered not to prove the truth of the matters asserted, but to prove the declarant's state of mind, such as their knowledge of specific facts, which can then be used to infer their presence at a particular location.

Facts:

• On February 26, 1945, a seven-year-old girl, Sharon Schunk, was walking home from school in Madison, Wisconsin.
• A man in a soldier's uniform approached her, stated he had some 'funny books,' and led her by the hand several blocks to a house.
• The man took her to a second-floor room where he committed an assault constituting the taking of indecent liberties.
• Upon returning home, Sharon told her mother and later, police, specific details about the house's exterior (wooden steps flanked by brick piers, near a small cottage with a white fence) and the room's interior (a dresser, a bed, dolls, and a picture of a lady).
• On March 27, 1945, police investigating the matter brought Sharon to 125 East Johnson Street, a house that matched her prior descriptions and was rented by the defendant, Bridges.
• Upon entering Bridges' room, Sharon recognized it and confirmed it was the location of the assault, pointing out specific items she had previously described.
• Bridges, a corporal in the U.S. Army who resided in that room, provided an alibi, claiming he was at home with his wife during the entire afternoon of the assault.
• Around the same time and in the same neighborhood as the assault on Sharon, another seven-year-old girl, Geraldine Shipley, was approached by a soldier, whom she later identified as Bridges, who engaged her in similar conversation and conduct.

Procedural Posture:

• The State of Wisconsin prosecuted Bridges in a state trial court for the crime of taking indecent liberties with a child.
• At trial, the court admitted, over Bridges' objections, testimony from the victim's mother and police officers recounting the victim's prior descriptions of the crime scene.
• The court also admitted, for the limited purpose of identification, testimony from another child about Bridges' similar conduct toward her on the same day.
• A jury convicted Bridges of the charged offense.
• The trial court entered a judgment of conviction based on the jury's verdict.
• Bridges (as plaintiff in error) appealed the conviction to the Supreme Court of Wisconsin, arguing the trial court committed prejudicial error by admitting the challenged testimony.