Wheeler v. United States
159 U.S. 523 (1895)
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Rule of Law:
A child's competency to testify is not determined by a specific age but by their individual capacity and intelligence, including their appreciation for the difference between truth and falsehood and their duty to be truthful, a determination which rests primarily with the trial judge and will not be disturbed on review absent clear error.
Facts:
- On June 12, 1894, a homicide occurred for which George L. Wheeler was subsequently charged.
- A key witness to the homicide was the son of the deceased, who was just under five years old at the time of the event.
- At the time of Wheeler's trial in December 1894, the boy was nearly five and a half years old.
- During a preliminary examination by the court (voir dire) to determine his competency, the boy stated that he knew the difference between truth and a lie.
- The boy also explained that if he told a lie, 'the bad man would get him' and that the court would put him in jail.
- He further stated that his mother had instructed him that morning to 'tell no lie.'
Procedural Posture:
- George L. Wheeler was tried for murder in the Circuit Court of the United States for the Eastern District of Texas, a federal trial court.
- During the trial, the court permitted the testimony of the deceased's five-year-old son over the defendant's objection.
- On January 2, 1895, Wheeler was adjudged guilty of murder and sentenced to be hanged.
- Wheeler appealed the conviction to the Supreme Court of the United States by suing out a writ of error.
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Issue:
Does a trial court commit reversible error by admitting the testimony of a five-year-old child witness who, upon examination, demonstrates an understanding of the difference between truth and falsehood and the consequences of lying?
Opinions:
Majority - Mr. Justice Brewer
No. A trial court does not err in admitting the testimony of a child witness when the judge, after a preliminary examination, determines the child has the capacity and intelligence to appreciate the difference between truth and falsehood and the duty to tell the truth. There is no precise age which determines the competency of a child witness; rather, it depends on the child's individual capacity and intelligence. The trial judge is in the best position to assess these factors, as they can directly observe the witness's manner and conduct any necessary examination. Therefore, an appellate court will not disturb the trial judge's decision on competency unless it is clearly erroneous. In this case, the child's answers during voir dire were sufficient to show he was intelligent and understood the nature and consequences of an oath, justifying the trial court's decision to admit his testimony.
Analysis:
This case solidifies the modern standard for determining child witness competency, shifting the focus from a rigid, age-based rule to a flexible, individualized assessment of the child's intelligence and moral understanding. By vesting primary discretion in the trial judge and establishing a highly deferential standard of review ('clear error'), the decision empowers trial courts to make nuanced judgments based on direct observation. This balances the need to protect defendants from unreliable testimony with the goal of ensuring that capable witnesses, regardless of age, can provide crucial evidence, thereby preventing a potential miscarriage of justice.
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