Pittsv.Mississippi
At Pitts’s trial, a physical screen prevented a child witness from seeing the defendant while testifying. Mississippi relied on a statute authorizing protective measures for child witnesses, but the trial court did not make a case-specific finding that the screen was necessary. The Supreme Court held that the Confrontation Clause requires an individualized necessity determination before a defendant’s face-to-face confrontation right may be restricted. A categorical legislative judgment cannot substitute for findings tied to the particular witness and proceeding. The judgment was reversed and the case remanded, leaving the state courts to address any preserved harmless-error question.
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