Idaho v. Wright, 497 U.S. 805 (1990)
Idaho v. Wright is a landmark Confrontation Clause decision at the intersection of criminal procedure and evidence, particularly in child sexual abuse prosecutions.
Whether the admission, under a residual hearsay exception, of a very young child's out-of-court statements to a physician identifying the defendant as the abuser violated the defendant's Sixth Amendment Confrontation Clause rights when the child was unavailable to testify and the statements' reliability was supported in part by corroborating evidence.
Under the Confrontation Clause framework of Ohio v. Roberts, if a hearsay declarant is unavailable, the statement is admissible only if it bears adequate indicia of reliability. Reliability is inferred when the hearsay falls within a firmly rooted exception; otherwise, it must be shown by particularized guarantees of trustworthiness. Those guarantees must be drawn from the totality of circumstances surrounding the making of the statement itself. Courts may not bolster reliability with independent corroborating evidence of the defendant's guilt.
Affirmed. The child's statements, admitted under the residual hearsay exception, did not possess the necessary particularized guarantees of trustworthiness, and the use of corroborating evidence to establish reliability violated the Confrontation Clause.
Wright is foundational in two ways. First, it squarely limits the use of the residual hearsay exception in criminal cases: when a declarant is unavailable and the hearsay is not within a firmly rooted exception, reliability must be proved by the statement's own circumstances, not by external corroboration. Second, although Crawford v. Washington later overhauled Confrontation Clause doctrine for testimonial hearsay, Wright remains important for evaluating reliability in contexts outside Crawford's testimonial core and for evidence law more broadly, especially in cases involving young children. For students, Wright teaches how to analyze child-hearsay admissions, to separate evidentiary admissibility from constitutional sufficiency, and to identify and weigh the intrinsic trustworthiness factors without bootstrapping.