Rock v. Arkansas

Vickie Rock (defendant) was charged with manslaughter after shooting her husband during a fight. Unable to recall the shooting clearly at first, she recovered a fuller memory after hypnosis by Dr. Back, recalling that the gun discharged accidentally when her husband grabbed her arm. The trial court found the hypnosis session untainted by leading questions, and an inspection confirmed the gun was defective and prone to firing without the trigger being pulled. Even so, Arkansas's per se rule barred any post-hypnosis testimony, so the trial court limited Rock to her pre-hypnosis recollections, and she was convicted. The Arkansas Supreme Court affirmed, and the U.S. Supreme Court granted certiorari.