Wyatt v. United States

Background

A man was tried and convicted for knowingly transporting a woman across state lines for the purpose of prostitution under the federal Mann Act. The woman had later married him. At trial the judge ordered her to testify for the prosecution over both her and her husband’s objections. The Court of Appeals affirmed, and the Supreme Court took the case to resolve questions about the spousal privilege against testifying.

Reasoning

The central question was whether the usual rule that lets a spouse keep from testifying against a partner can be used here. The Court said the old rule has a long-recognized exception for crimes committed against a spouse, and every federal appeals court to consider Mann Act cases had applied that exception. The Court emphasized Congress’ purpose in the Mann Act to protect women considered likely to lack independent will, and concluded that a prostituted wife cannot be allowed to refuse testimony that would otherwise deny justice. The Court therefore approved the trial court’s decision and affirmed the conviction.

Real world impact

Going forward, federal courts may require a wife who was the victim of interstate transportation for prostitution to testify against her husband even if she objects. The decision treats marriage after the offense as not shielding the husband from that rule. The ruling narrows the reach of the spousal testimonial protection in Mann Act prosecutions, though it is limited to cases of this kind.

Dissents or concurrances

Three Justices dissented, arguing the majority assumed the wife lacked independent will despite the record and that compelling a spouse to testify raises policy issues better left to Congress.