P.J.S., A Juvenile v. State of Florida
The Third DCA reversed delinquency adjudications entered after a hybrid hearing in which the judge appeared remotely via Zoom while witnesses, the juvenile, and attorneys were physically present, and a key prosecution witness testified masked. Following its recent line of decisions (M.D., J.T.B., and K.M.), the court held that due process in delinquency proceedings requires case-specific findings of necessity before conducting hearings in such hybrid/masked formats, and the record here contained no such particularized findings.
Key facts
- Juvenile P.J.S. was adjudicated delinquent in a hybrid hearing where the judge appeared remotely via Zoom while witnesses, the juvenile, and attorneys were physically present, and a key prosecution witness testified while masked.
- The trial court conducted the adjudicatory hearing without making any on-the-record case-specific findings of necessity to justify the hybrid format or masked testimony.
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Why it matters
This opinion continues a developing line of Third DCA precedent (M.D., J.T.B., K.M.) establishing that COVID-era remote/hybrid hearing arrangements and masked witness testimony in juvenile delinquency cases require… — full analysis with a trial
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