Coy v. Iowa

Supreme Court of United States
487 U.S. 1012 (1988)

ELI5:

Rule of Law:

The Sixth Amendment's Confrontation Clause guarantees a criminal defendant a physical, face-to-face meeting with witnesses who testify at trial, and this right is not satisfied by witness testimony from behind a screen that prevents the witness from seeing the defendant.

Facts:

Two 13-year-old girls were camping in a backyard tent next door to appellant John Avery Coy's house.
An assailant entered their tent while they were asleep.
The assailant, wearing a stocking over his head, shined a flashlight in the girls' eyes and warned them not to look at him.
Neither girl was able to describe the assailant's face.
Coy was subsequently arrested and charged with sexually assaulting the two girls.

Procedural Posture:

The State of Iowa prosecuted John Avery Coy in an Iowa state trial court for two counts of lascivious acts with a child.
Pursuant to a state statute, the trial court granted the State's motion to place a large screen between Coy and the two child witnesses during their testimony.
The jury returned a guilty verdict on both counts.
Coy, as appellant, appealed his conviction to the Iowa Supreme Court.
The Iowa Supreme Court, as appellee, affirmed the conviction, finding no violation of the Confrontation Clause.
The United States Supreme Court noted probable jurisdiction to review the decision of the Iowa Supreme Court.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does the use of a one-way screen, placed between a criminal defendant and two child witnesses during their testimony, violate the defendant's Sixth Amendment right to confrontation?

Opinions:

Majority - Justice Scalia

Yes. The use of the screen violates the defendant's Sixth Amendment right because the Confrontation Clause guarantees a literal right to a face-to-face encounter between the defendant and the witnesses testifying against him. The Court reasoned that this right to a physical, face-to-face meeting is the 'irreducible literal meaning of the Clause' and has deep historical roots essential to the perception and reality of a fair trial. The presence of the accused may unnerve a lying witness or reveal a coached one, serving a purpose similar to cross-examination in ensuring the integrity of the fact-finding process. While the Court has recognized exceptions to other rights implied by the Confrontation Clause (such as hearsay rules), it leaves for another day whether exceptions to the core face-to-face requirement exist. However, any such exception would require more than a generalized legislative finding of potential trauma; it would necessitate individualized findings that the specific witnesses need special protection, which were absent here.

Concurring - Justice O'Connor

Yes. The procedure used in this case violated the Confrontation Clause. However, the right to face-to-face confrontation is not absolute and may give way to other important interests, such as protecting child witnesses from trauma. While the 'preference' for face-to-face confrontation is at the core of the Clause, it can be overcome if a procedure is necessary to further a compelling public policy. This requires a case-specific finding of necessity—a determination that the particular child witness would be traumatized by testifying in the defendant's presence. Because the trial court made no such individualized finding of necessity, the use of the screen was unconstitutional in this case.

Dissenting - Justice Blackmun

No. The screening procedure did not violate the Confrontation Clause. The 'essence' of the confrontation right—ensuring testimony is given under oath, subject to full cross-examination, and in view of the jury—was fully protected. The defendant's interest in being seen by the witnesses is a mere 'preference,' not the core of the right, and it is outweighed by the significant state interest in protecting child sexual abuse victims from the trauma of testifying. The dissent argues that the majority overstates the importance of the witness viewing the defendant, and that a generalized legislative determination of necessity is sufficient to justify such a protective measure, without requiring a case-by-case showing of need.

Analysis:

This decision firmly established that the Confrontation Clause provides a right to a literal, physical, face-to-face encounter, separate and distinct from the right to cross-examination. It set a high constitutional bar for state procedures designed to protect child witnesses, such as one-way screens or closed-circuit television where the witness cannot see the defendant. The holding, especially as clarified by Justice O'Connor's concurrence, created a requirement for an individualized, case-specific finding of necessity before a defendant's core confrontation right can be limited. This forced state legislatures and courts to refine their child-witness protection statutes to include hearings to determine whether a specific child would suffer trauma from testifying, rather than relying on a blanket statutory presumption.

Gunnerbot

AI-powered case assistant

Loaded: Coy v. Iowa (1988)

Try: "What was the holding?" or "Explain the dissent"

Premium Feature