Testimonial Privilege Underwood argues that, even if the child-abuse exception applies, the district court violated due process when it failed to affirmatively find that Cora knew she had a voluntary right to refuse to testify. Underwood cannot raise this claim. The witness-spouse alone has a privilege to refuse to testify adversely. Trammel v. United States, 445 U.S. 40, 53, 100 S.Ct. 906, 63 L.Ed.2d 186 (1980). Therefore, Underwood holds no right to the privilege and thus lacks standing to raise the issue on appeal. See United States v. Anderson, 39 F.3d 331, 350 (D.C. Cir. 1994) (finding defendant-spouse without standing to contest a district court’s decision to compel the spouse to testify) (vacated on other grounds); United States v. Lofton, 957 F.2d 476, 477 n.1 (7th Cir. 1992) (<HOLDING>); Grand Jury Subpoena of Ford v. United States,
holding that lofton would have no standing to appeal the district courts determination that his wife waived her spousal testimonial privilege holding individual standing issue waived holding the government waived its argument on appeal that the defendant did not have standing to challenge a search when it failed to raise the argument to the district court holding that a district courts determination as to the applicability of a privilege is reviewed for clear error holding trial court erred in finding purported wife unavailable to testify and admitting her sworn prior statements in lieu of her live testimony where record did not support courts ruling in light of its own finding that remarriage of wife and defendant was fraudulent and wife did not refuse to testify if claim of privilege was denied