I.P. v. State
In a juvenile delinquency case, I.P. objected to conducting part of his adjudicatory hearing remotely via Zoom, with some witnesses testifying remotely while the judge, counsel, and I.P. appeared in person. The trial court overruled the objection without making case-specific findings justifying the need for remote testimony, and the Third DCA reversed and remanded for a new adjudicatory hearing, relying on its recent precedent in M.D. v. State, J.T.B. v. State, and the Second DCA's T.H. v. State.
Key facts
- I.P., a juvenile, was charged in a delinquency proceeding and objected to conducting part of his adjudicatory hearing remotely via Zoom, with some witnesses testifying remotely while the judge, counsel, and I.P. appeared in person.
- The trial court overruled I.P.'s objection without making case-specific findings justifying the need for remote testimony.
- +1 more key fact with a free trial
Why it matters
This per curiam opinion reinforces a growing and consistent line of Third and Second DCA authority holding that courts must make case-specific findings before conducting remote testimony or hearings over a defendant's… — full analysis with a trial
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