Motes v. United States, 178 U.S. 458 (1900)
In Motes v. United States, the U.S. Supreme Court held that an accused has been deprived of his Sixth Amendment right to confront his accuser when the witness who had testified against the accused disappeared prior to allowing the accuser an opportunity to cross-examine the witness.
After a preliminary trial before the U.S. commissioner in which Jasper Taylor testified to the guilt of Walter Motes and him, and for which testimony Motes had the opportunity to cross-examine Taylor, Motes and Taylor were formally accused of murder and conspiracy to murder. At the actual trial, Taylor was called to testify against Motes, but disappeared an hour before his testimony due to the negligence of the officer guarding him. The prosecution submitted Taylor’s previous testimony from the preliminary trial to the jury over the objection of Motes’s counsel. Motes was convicted and appealed unsuccessfully to the court of appeals and to the Supreme Court.
The Supreme Court held that Motes had not procured the absence of the witness and had been denied the opportunity to cross-examine the witness before the jury. However, the Court affirmed the conviction due to Motes’s voluntary confession as to his guilt. In addition, the Court found that in criminal cases a question of interpretation of a constitutional right cannot depend upon the rules of evidence prevailing in the courts of the state in which the crime was committed, but is controlled by the Constitution and the Court’s interpretations of the Constitution.
DAVID M. CARR
References and Further Reading
- Nance, Dale A., Rethinking Confrontation After Crawford, International Commentary on Evidence 2(1) Article 2., https://www.bepress.com/ice/vol2/iss1/art2 (2004).
Cases and Statutes Cited
- American Construction Co. v. Jacksonville Railway Co., 158 U.S. 372
- Ex parte Yarborough, 110 U.S. 651
- Logan v. United States, 144 U.S. 263
- Lowe v. State, 86 Ala. 47
- Pruitt v. State, 92 Ala. 41
- Regina v. Scaife, 2 Den. Cr. C. 281
- Reynolds v. United States, 98 U.S. 145
- United States v. Rider, 163 U.S. 132
- United States v. Waddell, 112 U.S 76
- Revised Statutes of the United States, }} 5508-9
See also Confrontation Clause