In Snyder v. Massachusetts, 291 U.S. 97, 78 L. Ed. 674, 54 S. Ct. 330 (1934), the Supreme Court outlined the parameters of a defendant's due process right to be present during trial. The Court said "whenever the defendant's presence has a relation, reasonably substantial, to the fullness of his opportunity to defend against the charge" the defendant has a right to be present. The "presence of a defendant is a condition of due process to the extent that a fair and just hearing would be thwarted by his absence, and to that extent only." Id. at 105-106, 108.