Coy v. Iowa

Background

A man was tried and convicted on two counts of lascivious acts after two 13-year-old girls said a masked attacker entered their tent, shined a flashlight in their eyes, and told them not to look. At trial Iowa allowed the girls to testify from behind a one-way screen under a new statute. The defense objected on confrontation and due process grounds, but the Iowa Supreme Court affirmed.

Reasoning

The Court considered whether the screen denied the defendant his Sixth Amendment right to face-to-face confrontation. Justice Scalia wrote that the Clause guarantees a literal face-to-face encounter and the one-way screen prevented that right. Exceptions, if any, must be necessary to further important public policies and require more than a broad legislative presumption. Because the Iowa law made no individualized findings and was recent, the Court found a constitutional violation, reversed, and remanded, leaving harmless-error review to the lower court.

Real world impact

The ruling means courts cannot rely solely on a statute that presumes child witnesses need shielding to justify denying face-to-face confrontation. States using one-way screens will have to satisfy constitutional requirements, and judges may need to make case-specific findings before blocking in-person sight. The decision also sends the harmless-error question back to the lower courts, so convictions affected by such screening may be reassessed on remand.

Dissents or concurrances

Justice O'Connor (joined by Justice White) agreed a violation occurred but stressed confrontation rights are not absolute and said case-specific necessity findings might permit protective procedures; Justice Blackmun (joined by the Chief Justice) would have upheld the conviction because cross-examination and jury observation remained and the screen was not inherently prejudicial.