2 legal cases involving hypnosis have recently been adjudicated by American courts. In Rock v. Arkansas (1987), the United States Supreme Court ruled that the hypnotically elicited testimony of a criminal defendant was admissible in court. This decision was grounded upon the constitutional right of a defendant both to testify, and to call witnesses, on his or her own behalf. Shortly afterwards, citing Rock as a precedent, a Texas Court of Appeals admitted the hypnotically elicited testimony of an eyewitness in Zani v. State (1988), on the grounds that it would be unfair to admit the hypnotically elicited testimony of defendants, and proscribe it for victims and witnesses. It is not clear what effect this doctrine of equity will have upon other North American court cases that involve hypnosis.