“Hearsay of the Sun”: The Murder of Winfield Scott Goss and Nineteenth-Century Photography on Trial

ABSTRACT In 1873, William Udderzook of Baltimore stood trial for the murder of his brother-in-law, Winfield Scott Goss, in Chester County, Pennsylvania. During the almost two-week-long trial, the story of Goss and Udderzook’s life insurance fraud, culminating in Goss’s very real death at the hands of his co-conspirator, dominated newspaper headlines. Due to the influence of the insurance companies over the investigation and trial, the criminal indictment against Udderzook created one of the most complicated cases ever tried in the Commonwealth. The case depended on the use of a photograph, resulting in a Supreme Court decision that forever changed the way evidence could be used. This article analyzes the crime, the trial testimony, and the appeal process to establish the treatment of photography in courts of law prior to the Udderzook case, and how its use nationwide changed in the wake of the Pennsylvania Supreme Court decision in 1874.