In re Juvenile Appeal
In In re Juvenile Appeal, 187 Conn. 431, 446 A.2d 808, 813 (Conn. 1982), an incarcerated father received transcripts of a first hearing and discussed the testimony with counsel. 446 A.2d at 811-12.
The father was able to participate at a second hearing three months later, where "a speaker was attached to a telephone at the court in Connecticut and the respondent testified from his California prison; his voice was audible to all those attending the hearing." Id. at 812.
The court held that the procedure did not violate the father's due process rights on the theory that it weakened the efficacy of his cross-examination; where he had adequate time for perusal of testimony and for consultation with his attorney; he declined court's offer to defer cross-examination until he had seen the transcript; and there was no showing that the cross-examination was defective or incomplete. Id.