Do the Rules of Evidence Differ at Preliminary Hearings vs. Trials?
Yes, the rules of evidence at a preliminary hearing are not as strict as those applied at a trial. In Kansas, the rules of evidence are more relaxed during a preliminary hearing, allowing the use of evidence that may not necessarily be admissible during trial. The case State v. Earley, 386 P.2d 189 (Kan. 1963) clarifies this distinction and explains how evidence rules differ at these two stages.
Issue: Are the Evidence Rules the Same at a Preliminary Hearing and at Trial?
The main issue in State v. Earley was whether the rules of evidence at a preliminary hearing should follow the same strict standards as those applied during a trial. Specifically, the case examined whether hearsay and other types of evidence typically barred at trial could be allowed at a preliminary hearing. The court ultimately held that the rules of evidence at preliminary hearings are indeed more relaxed than at trial.
Facts of the Case
In State v. Earley, three men, including Earley, were arrested after police found burglary tools in their car following a nighttime stop near a local high school. They were subsequently bound over for trial after a preliminary hearing, during which the defendants argued that the evidence obtained from their arrest was inadmissible because the arrest itself was illegal. They also contended that no probable cause existed to justify their arrest.
After the district court denied their applications for habeas corpus, which sought to challenge the legality of their arrest and the admissibility of the evidence, the case was brought to the Kansas Supreme Court. The defendants argued that the evidence obtained from the search should not have been used during the preliminary hearing due to its inadmissibility at trial.
Court’s Analysis: Relaxed Rules of Evidence at Preliminary Hearings
The Kansas Supreme Court ruled that the strict rules of evidence, such as those governing hearsay, are not required at a preliminary hearing. The purpose of a preliminary hearing is different from a trial in several key ways:
Purpose of a Preliminary Hearing: A preliminary hearing is designed to determine if there is enough evidence (probable cause) to believe that a crime has been committed and that the defendant is connected to it. It is not meant to establish the defendant’s guilt or innocence. Rather, the hearing provides general information about the nature of the charges against the defendant and gives the defendant an idea of the evidence that will be presented at trial.
Hearsay Evidence: The court emphasized that hearsay is allowed at a preliminary hearing when statutes authorize it. Although hearsay evidence is generally inadmissible at trial, it can be used during a preliminary hearing to meet the lower standard of proof required at that stage. The court held that relaxing the rules of evidence for preliminary hearings is constitutional and does not violate the defendant’s rights.
Less Rigorous Standard: The preliminary hearing does not need to meet the same evidentiary rigor as a trial. The court found that even if some of the evidence presented at the preliminary hearing might later be ruled inadmissible at trial, it could still be considered at the preliminary hearing. The purpose of this relaxed standard is to ensure that the defendant is aware of the nature of the evidence and charges against them, even if some evidence might not meet the strict requirements of trial.
Probable Cause vs. Proof Beyond a Reasonable Doubt: The standard of proof at a preliminary hearing is probable cause, which is a much lower threshold than the proof beyond a reasonable doubt required at trial. This difference in the burden of proof justifies the use of evidence that might not be admissible at trial to establish probable cause at the preliminary stage.
Court’s Ruling
The Kansas Supreme Court affirmed the district court’s decision, holding that the relaxed rules of evidence at a preliminary hearing were appropriate. The court concluded that the preliminary hearing in Earley's case served its intended purpose of informing the defendants of the charges and the general evidence against them, even if some of that evidence would not be admissible at trial. Therefore, the district court did not err in denying the defendants’ habeas corpus petitions.
Key Takeaways from the Ruling
Relaxed Rules of Evidence: The rules of evidence at a preliminary hearing are more lenient than at trial. Courts allow evidence such as hearsay at the preliminary hearing stage when a statute authorizes its use, even though this evidence would not be admissible at trial.
Purpose of the Preliminary Hearing: The purpose of a preliminary hearing is to establish probable cause and provide the defendant with information about the charges and the evidence, not to determine guilt or innocence. The evidence presented is primarily aimed at demonstrating that the case should proceed to trial.
Probable Cause Standard: A lower standard of proof—probable cause—is used at preliminary hearings, which justifies the admission of evidence that might not meet the strict standards required at trial.
Trial vs. Preliminary Hearing: While trials are focused on determining guilt beyond a reasonable doubt with stringent rules on admissibility of evidence, preliminary hearings serve as a procedural step to ensure there is enough evidence to continue with the prosecution, and therefore, a more flexible approach to evidence is permitted.
Conclusion
The evidence rules at a preliminary hearing in Kansas are not the same as at trial. Courts allow hearsay and other forms of evidence that might not be admissible at trial because the purpose of the preliminary hearing is simply to establish probable cause and provide the defendant with general information about the case. The relaxed evidentiary rules help ensure that the case can proceed to trial without requiring the same level of formality and rigor expected during a full trial.