views of each other, but the high court emphasized that the finding[s]” or “generalized imposed presumption of trauma” to the witnesses, underlying the Iowa “legislatively statute, were insufficient to justify depriving the defendant of his Sixth Amendment right to face the witnesses at trial. (Ibid.) stated: there have been no Coy “Since individualized findings that these particular witnesses needed special protection, the judgment here could not be sustained by any conceivable exception.” (Ibid.) In 1990, two years after was decided in 1988, clarified that the right to Coy Craig face-to-face confrontation is not absolute, and alternative procedures may be used when it is shown that (1) such procedures are to further an important public policy,” “necessary and (2) reliability of the testimony is otherwise assured.” (Craig, 497 U.S. at supra, “the pp. 849-850.) involved a six-year-old alleged child abuse victim who testified Craig against the defendant by one-way closed-circuit television. The defendant, the trial judge, and the jury were in the courtroom while the child was in another room being examined by the prosecutor and defense counsel. A video monitor recorded and displayed the child’s testimony to those in the courtroom. The child could not see the defendant as she testified, but the defendant could see the child, and the defendant was in electronic communication with her defense counsel while the child testified. (Id. at pp. 840-842.) Regarding the reliability of the child’s testimony, emphasized that the Craig Maryland statute preserved all of the elements of the right to confrontation: “other” “The child witness must be competent to testify and must testify under oath; the defendant
views of each other, but the high court emphasized that the “generalized finding[s]” or “legislatively imposed presumption of trauma” to the witnesses, underlying the Iowa statute, were insufficient to justify depriving the defendant of his Sixth Amendment right to face the witnesses at trial. (Ibid.) Coy stated: “Since there have been no individualized findings that these particular witnesses needed special protection, the judgment here could not be sustained by any conceivable exception.” (Ibid.) In 1990, two years after Coy was decided in 1988, Craig clarified that the right to face-to-face confrontation is not absolute, and alternative procedures may be used when it is shown that (1) such procedures are “necessary to further an important public policy,” and (2) “the reliability of the testimony is otherwise assured.” (Craig, supra, 497 U.S. at pp. 849-850.) Craig involved a six-year-old alleged child abuse victim who testified against the defendant by one-way closed-circuit television. The defendant, the trial judge, and the jury were in the courtroom while the child was in another room being examined by the prosecutor and defense counsel. A video monitor recorded and displayed the child’s testimony to those in the courtroom. The child could not see the defendant as she testified, but the defendant could see the child, and the defendant was in electronic communication with her defense counsel while the child testified. (Id. at pp. 840-842.) Regarding the reliability of the child’s testimony, Craig emphasized that the Maryland statute preserved all of the “other” elements of the right to confrontation: “The child witness must be competent to testify and must testify under oath; the defendant
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