## Facts

- James W. Snyder was prosecuted in federal court for child-pornography offenses involving an eleven-year-old victim.
- The government’s case relied heavily on the child victim’s testimony.
- During cross-examination, defense counsel highlighted multiple inconsistencies and demonstrably false statements in the child’s testimony.
- The defense moved for a court-ordered psychological or psychiatric examination of the child to assess competency, citing the false statements and the child’s use of antidepressant medication.
- The district court denied the request for psychological testing and allowed the child to testify.
- Snyder was convicted and appealed, arguing the competency ruling and denial of testing deprived him of a fair trial.

## Issues

1. Whether the district court abused its discretion by refusing to order psychological testing to assess the competency of an eleven-year-old witness after impeachment showing false statements and evidence the witness took antidepressants.
2. Whether the witness’s inconsistencies and medication required exclusion of the testimony on competency or due process grounds.

## Decision

- The Seventh Circuit affirmed the conviction.
- The court held the district court did not abuse its discretion in declining to order psychological testing of the child witness.
- The court concluded that inconsistencies and the use of antidepressant medication did not, without more, establish incompetency to testify.
- The court treated the defense challenges as matters for the jury’s evaluation of credibility and weight, addressed through cross-examination.

## Legal Principles

- Witness competency is a threshold determination for the judge and generally requires the ability to understand the duty to tell the truth and to communicate intelligibly.
- Inconsistencies, memory problems, and other impeachment points typically bear on credibility and weight, not competency.
- There is no general right to court-ordered psychological or psychiatric testing of a witness; ordering such testing lies within the trial court’s discretion and is reviewed for abuse of discretion.
- A witness’s use of antidepressant medication does not by itself establish incompetency absent evidence of impairment affecting the ability to perceive, communicate, or understand truthfulness.
- Due process is ordinarily satisfied when the defendant can meaningfully cross-examine the witness and argue credibility to the jury; discretionary competency/testing rulings do not become constitutional error solely because the defense disputes reliability.

## Conclusion

The Seventh Circuit upheld Snyder’s conviction, holding that the trial court acted within its discretion in declining to order psychological testing of the child witness and that the asserted defects in the child’s testimony and medication use went to credibility for the jury rather than competency requiring exclusion.


United States v. Snyder, 189 F.3d 640 (7th Cir. 1999)