the courtroom. (Id. at pp. 841, 843.) The trial court found the accommodation necessary after the prosecution presented expert testimony the child witnesses, one of whom was six years old, suffer emotional distress such that [they could not] reasonably “would ‘serious communicate.’” (Id. at p. 842, brackets in original.) In upholding the accommodation, the Supreme Court announced a new rule: hold that, if the State makes an “[W]e adequate showing of necessity, the state interest in protecting from the child witnesses trauma of testifying in a child abuse case is sufficiently important to justify the use of a special procedure that permits a child witness in such cases to testify at trial against a defendant in the absence of face-to-face confrontation with the defendant.” (Id. at p. 855, italics added.) established a two-part test. First, trial court must hear evidence and Craig “[t]he determine whether” the accommodation necessary to protect the welfare of the “is particular who seeks to testify.” (Craig, 497 U.S. at p. 855, italics child witness supra, added.) The trial court must then make a finding” that child witness “case-specific “the would be if made to face the defendant in court. (Id. at pp. 855-856, 860, traumatized” italics added.) De minimis distress” like or excitement or some “emotional “nervousness reluctance to testify” will not suffice. (Id. at pp. 841-842, 855-856, 860.) Second, because it will invade the to face-to-face confrontation, the accommodation must preserve the confrontation right’s other of “safeguards reliability”—“oath, cross-examination, and observation of the witness’ demeanor.” (Craig, 497 U.S. at p. 851.) The Supreme Court approved of Maryland’s statutory supra, procedure because it ensured that defendant retains full opportunity for “the
the courtroom. (Id. at pp. 841, 843.) The trial court found the accommodation necessary after the prosecution presented expert testimony the child witnesses, one of whom was six years old, “would suffer ‘serious emotional distress such that [they could not] reasonably communicate.’” (Id. at p. 842, brackets in original.) In upholding the accommodation, the Supreme Court announced a new rule: “[W]e hold that, if the State makes an adequate showing of necessity, the state interest in protecting child witnesses from the trauma of testifying in a child abuse case is sufficiently important to justify the use of a special procedure that permits a child witness in such cases to testify at trial against a defendant in the absence of face-to-face confrontation with the defendant.” (Id. at p. 855, italics added.) Craig established a two-part test. First, “[t]he trial court must hear evidence and determine whether” the accommodation “is necessary to protect the welfare of the particular child witness who seeks to testify.” (Craig, supra, 497 U.S. at p. 855, italics added.) The trial court must then make a “case-specific finding” that “the child witness would be traumatized” if made to face the defendant in court. (Id. at pp. 855-856, 860, italics added.) De minimis “emotional distress” like “nervousness or excitement or some reluctance to testify” will not suffice. (Id. at pp. 841-842, 855-856, 860.) Second, because it will invade the to face-to-face confrontation, the accommodation must preserve the confrontation right’s other “safeguards of reliability”—“oath, cross-examination, and observation of the witness’ demeanor.” (Craig, supra, 497 U.S. at p. 851.) The Supreme Court approved of Maryland’s statutory procedure because it ensured that “the defendant retains full opportunity for
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