Additionally, does not the outer boundary” of when alternative Craig “mark[] procedures to face-to-face confrontation are constitutionally permissible. (Lujan, supra, 211 Cal.App.4th at p. 1505.) Trial courts have conferred, inherent “constitutionally authority to new forms of procedure’ in the gaps left unaddressed by statutes and ‘create the rules of court. [Citations.]” (Id. at p. 1507.) But courts may not sanction new procedures that are of constitutional validity.” (In (1993) 15 re Amber S. “dubious Cal.App.4th 1260, 1266.) Whether the trial court has a particular inherent authority is a question of law subject to de novo review, and the court’s exercise of its inherent authority is reviewed for an abuse of discretion. (Lujan, at p. 1507.) supra, We discern no constitutional validity” or abuse of discretion in the trial “dubious court’s decision to allow the computer monitor to be raised to protect 18-year-old 11th grade high school student F.R. from the emotional trauma of facing defendant while testifying, and, indeed, to enable F.R. to testify. (Sharp, 29 Cal.App.4th at p. supra, 1783.) recognized that the right to face-to-face confrontation is not Craig “an indispensable element of the Sixth’s Amendment’s guarantee of the right to confront one’s accusers,” and that the right occasionally give way to considerations of “‘must public policy and the necessities of the case.’” (Craig, 497 U.S. at pp. 849-850.) supra, and also recognized that the state’s important interest in obtaining a Sharp Gonzales witness’s testimony must be the right of the accused to face his or her balanced against accusers in court. (Sharp, at p. 1783; 54 Cal.4th at p. 1267.) supra, Gonzales, supra,
Additionally, Craig does not “mark[] the outer boundary” of when alternative procedures to face-to-face confrontation are constitutionally permissible. (Lujan, supra, 211 Cal.App.4th at p. 1505.) Trial courts have “constitutionally conferred, inherent authority to ‘create new forms of procedure’ in the gaps left unaddressed by statutes and the rules of court. [Citations.]” (Id. at p. 1507.) But courts may not sanction new procedures that are of “dubious constitutional validity.” (In re Amber S. (1993) 15 Cal.App.4th 1260, 1266.) Whether the trial court has a particular inherent authority is a question of law subject to de novo review, and the court’s exercise of its inherent authority is reviewed for an abuse of discretion. (Lujan, supra, at p. 1507.) We discern no “dubious constitutional validity” or abuse of discretion in the trial court’s decision to allow the computer monitor to be raised to protect 18-year-old 11th grade high school student F.R. from the emotional trauma of facing defendant while testifying, and, indeed, to enable F.R. to testify. (Sharp, supra, 29 Cal.App.4th at p. 1783.) Craig recognized that the right to face-to-face confrontation is not “an indispensable element of the Sixth’s Amendment’s guarantee of the right to confront one’s accusers,” and that the right “‘must occasionally give way to considerations of public policy and the necessities of the case.’” (Craig, supra, 497 U.S. at pp. 849-850.) Sharp and Gonzales also recognized that the state’s important interest in obtaining a witness’s testimony must be balanced against the right of the accused to face his or her accusers in court. (Sharp, supra, at p. 1783; Gonzales, supra, 54 Cal.4th at p. 1267.)
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