M.L.K. III v. State
The First DCA reversed an indirect criminal contempt finding against a father, holding that his removal from the courtroom during a minor witness's remote testimony—without any means to observe, hear, or communicate directly with counsel during that testimony—violated his Sixth Amendment confrontation rights. The court found the procedure failed to satisfy either the Maryland v. Craig standard or the specific safeguards required by section 92.54, Florida Statutes, for remote child witness testimony. Judge Winokur concurred separately to flag the unresolved tension between Craig and Crawford v. Washington regarding the continued validity of Craig's balancing approach.
Key facts
- Father was found in indirect criminal contempt after being removed from the courtroom during a minor witness's remote testimony without ability to observe, hear, or communicate with his counsel.
- The trial court permitted the child witness to testify remotely while excluding the father from the courtroom, limiting his access to counsel during the proceedings.
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Why it matters
This decision is useful to practitioners handling any criminal or quasi-criminal (e.g., indirect criminal contempt) proceeding involving remote or accommodated testimony of a minor witness, clarifying that mere physical… — full analysis with a trial
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