Pitts v. Mississippi
607 U. S. ____ (2025) (2025)
Rule of Law:
Under the Sixth Amendment's Confrontation Clause, a court may not permit a child witness to testify behind a screen without first holding a hearing and making a case-specific finding that the screen is necessary to protect the child from trauma that would impair the child's ability to communicate. A state statute that makes such screening mandatory is unconstitutional.
Facts:
- In May 2020, a child, A. G. C., spent a weekend visiting her father, Jeffrey Pitts.
- After returning home, A. G. C. informed her mother that Pitts had sexually abused her.
- This allegation led to criminal charges being filed against Pitts.
- At the time of the trial, A. G. C. was four years old.
Procedural Posture:
- The State of Mississippi criminally charged Jeffrey Pitts in a state trial court.
- At trial, the State moved to place a screen between the child witness, A. G. C., and Pitts, citing a mandatory Mississippi statute.
- The trial judge granted the State's motion, expressing concern about failing to follow the mandatory statute.
- A jury convicted Pitts.
- Pitts, as appellant, appealed to the Mississippi Supreme Court, arguing the trial court violated his Sixth Amendment rights by not making a case-specific finding of necessity for the screen.
- A divided Mississippi Supreme Court, with the State as appellee, rejected Pitts's argument and affirmed the conviction.
- Pitts petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a state statute that grants child witnesses a mandatory right to testify behind a screen, without requiring a case-specific judicial finding of necessity, violate a defendant's Sixth Amendment right to a face-to-face confrontation?
Opinions:
Per_curiam - Per Curiam
Yes, a state statute mandating the use of a screen for a child witness without a specific judicial finding of necessity violates the Sixth Amendment's Confrontation Clause. The precedents of Coy v. Iowa and Maryland v. Craig establish that any deviation from a defendant's right to face-to-face confrontation requires the trial court to hear evidence and make a case-specific finding that the procedure is necessary to protect a child witness from trauma that would impair their ability to communicate. A state law, whether permissive or mandatory, cannot substitute for this individualized judicial determination, as generalized legislative findings are insufficient. The Mississippi Supreme Court's attempts to distinguish this case from precedent—by citing a state victims' rights provision, the mandatory nature of the statute, the child's young age, or the type of screen used—are unpersuasive because the Supremacy Clause dictates that the U.S. Constitution controls over conflicting state law, and any infringement on the confrontation right requires the same specific finding of necessity. The trial court failed to make such a finding, instead deferring to the unconstitutional state statute.
Analysis:
This per curiam opinion strongly reaffirms the principles established in Maryland v. Craig, emphasizing that the procedural safeguards for infringing upon a defendant's confrontation rights are not optional. It clarifies that states cannot legislate around this constitutional requirement by creating mandatory, categorical exceptions for certain classes of witnesses, such as children. The decision underscores the judiciary's role in making individualized assessments of necessity, ensuring that the defendant's constitutional rights are balanced against the state's compelling interest in protecting child witnesses on a case-by-case basis. By remanding for a harmless-error analysis, the Court also acknowledges that such a constitutional violation does not automatically require a new trial, preserving judicial efficiency where the error did not affect the outcome.
