Coronado v. State

In Coronado v. State, 351 S.W.3d 315 (Tex. Crim. App. 2011), the child victim did not testify, and pursuant to section 2 of article 38.071, written interrogatories were used in lieu of the child's live testimony. Id. at 318-19; see Tex. Code Crim. Proc. Ann. art. 38.071, 2 (West Supp. 2014). The Court of Criminal Appeals held that the procedure authorized by section 2 of article 38.071 violated a defendant's right to confront witnesses and, thus, was unconstitutional. Coronado, 351 S.W.3d at 316.