Maryland v. Craig

The trial court set her up in a separate room with the judge, the prosecutor, and the defense attorney, so that the defendant and jury could only see her testify via the live television screen in the courtroom, and she could not see them.

Justice O'Connor noted that the fundamental purpose of the Sixth Amendment was to prevent ex parte affidavits, citing Mattox v. United States 156 U.S. 237, 242 (1895).

She further identified four primary guarantees embodied in the Confrontation Clause: The Court noted that hearsay exceptions demonstrated that no defendant had an absolute right to a face-to-face encounter with adversarial witnesses.

The State's interest in the physical and psychological well-being of child abuse victims could outweigh the defendant's right to face his accusers in court.

[1] During the COVID-19 pandemic, federal courts conducting criminal trials, relied upon Craig to have witnesses testify by "Zoom or some other videoconferencing technology.