Coy v. Iowa

Supreme Court of the United States · 1988 · Evidence

487 U.S. 1012 (1988)

Updated August 1, 2026

Evidenceface-to-face confrontationConfrontation ClauseSixth Amendmentface-to-face encounterchild witnessesscreening deviceindividualized findings

Facts

Appellant was charged with sexually assaulting two 13-year-old girls who were camping in a tent next to his house. At trial, the State moved under an Iowa statute to allow the girls to testify either by closed-circuit television or behind a screen, and the trial court approved a large screen between appellant and the witness stand. With courtroom lighting adjusted, appellant could dimly perceive the witnesses, but the witnesses could not see him at all while testifying. Appellant objected on Confrontation Clause and due process grounds, but the trial court overruled the objections and instructed the jury not to infer guilt from the screen.

Issue

Whether a trial procedure that prevents complaining witnesses from seeing the defendant while they testify violates the Sixth Amendment right to be confronted with the witnesses against him. Also, if so, whether the violation could be justified by the State's interest in protecting child sexual-abuse victims based only on a statutory presumption of trauma.

Rule

The Confrontation Clause guarantees a criminal defendant a face-to-face meeting with witnesses appearing before the trier of fact at trial. Even if exceptions to that literal guarantee may exist, they would be permitted only when necessary to further an important public policy, and a generalized legislative finding such as a statutory presumption of trauma is insufficient; at minimum, individualized findings are required where the exception is not firmly rooted.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a criminal trial in Des Moines, 12-year-old Maya Trent testifies that Nolan Price assaulted her. At the prosecutor's request, the judge places an opaque partition between the witness stand and defense table so that Maya cannot see Nolan, though Nolan can hear her and defense counsel conducts full cross-examination in front of the jury.

Under the controlling rule, is Nolan's Sixth Amendment confrontation right most likely violated?

Explanation. The majority held that the Confrontation Clause guarantees a criminal defendant a face-to-face meeting with witnesses appearing before the trier of fact at trial. A device specifically designed to prevent the witness from seeing the defendant is an obvious denial of that protection. The availability of cross-examination does not by itself cure the violation.