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However the deaf and dumb may have been regarded in times past and in other countries, the Supreme Court of Missouri holds, in the case of State v. Howard, decided Nov. 21,1893, that the presumption that a person deaf and dumb from birth should be deemed an idiot does not seem to obtain in modern practice,—at least in the United States. Such unfortunate persons may be witnesses, if able to communicate their ideas by signs, through the medium of an interpreter, or by writing, if they write and read writing.
LEGAL PRESUMPTION AS TO THE DEAF AND DUMB.. JAMA. 1894;XXII(6):196. doi:10.1001/jama.1894.02420850024009