Coy v. Iowa

In Coy v. Iowa, 487 U.S. 1012 (1988) a sex abuse prosecution, the Supreme Court found the state statute allowing for the placement of a screen between the child witnesses and the defendant to be unconstitutional. The Court found that the procedure impermissibly infringed upon defendant's confrontation rights because it was based upon a statutory presumption that the child witnesses would suffer trauma were they required to testify in defendant's presence (487 US at 1021). The U.S. Supreme Court found it unnecessary to decide whether any exceptions existed to the right to face-to-face confrontation at that, but did state that any exception to this right "would surely be allowed only when necessary to further an important public policy." Id. at 1021. In determining that the Iowa statute in question in Coy violated the defendant's right to confrontation the Supreme Court suggested that something more than the generalized finding underlying the "legislatively imposed presumption of trauma" contained in the statute involved in that case was necessary to overcome this constitutional right. The Supreme Court held that because there had been no "individualized findings that these particular witnesses needed special protection" the judgment could not be sustained. The Supreme Court addressed the placement of a screen between a testifying child and the child's accused abuser pursuant to an Iowa statute presuming trauma to a child witness. 487 U.S. at 1014. The screen blocked the defendant from the child's sight but allowed the defendant to see the child. Id. at 1014-15. The majority held that the screen violated the Sixth Amendment's guarantee of face-to-face confrontation. Id. at 1022. The Court left open the question of whether there were any exceptions to the face-to-face confrontation guarantee, noting that if there were they would only be allowed "to further an important public policy." Id. at 1021. Justice O'Connor concurred, stating that she would permit the use of a trial procedure that did not require face-to-face confrontation if it "were necessary to further an important public policy," such as a case-specific finding that the alternative procedure was necessary to protect a child witness. Id. at 1025 (O'Connor, J., concurring).