Survey of Washington Law: Evidence

Donald Porter, Survey of Washington Law: Evidence, 24 Gonz. L. Rev. 381 (1988).

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The Washington Supreme Court, in the case of State v. Coe, held that identification testimony of previously hypnotized victims is inadmissible. As a result of this decision, two of three rape convictions against Frederick H. “Kevin” Coe were reversed.

In its prior decision in State v. Coe (1984), the Washington Supreme Court reversed four rape convictions against Coe and remanded with instructions that the trial court adhere to the holding in State v. Martin. Specifically, the court held that upon remand “testimony as to facts recalled during hypnosis would be inadmissible,” and “testimony of the previously hypnotized witnesses would be admissible if the State can show that the testimony consists solely of prehypnotic memory.” . . . Read More

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