L.T.G. v. State
A juvenile challenged his delinquency adjudication after appearing remotely by cell phone via Zoom during a hybrid hearing and being repeatedly disconnected, after which the trial court denied his motion for mistrial. The Third DCA held that the juvenile did not voluntarily absent himself and that any waiver of his right to be physically present must be personal, knowing, intelligent, and voluntary—not one made by counsel—so it reversed and remanded for a new adjudicatory hearing.
Key facts
- Juvenile L.T.G. was adjudicated delinquent after appearing remotely via Zoom cell phone during a hybrid hearing in which he was repeatedly disconnected.
- The trial court denied the juvenile's motion for mistrial despite the technical disconnections during the remote appearance.
- +2 more key facts with a free trial
Why it matters
With hybrid and remote hearings increasingly common post-pandemic, this opinion gives juvenile defense practitioners a clear precedent that technical disconnections during a Zoom appearance can void a waiver of the… — full analysis with a trial
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