T.H. v. State
The Second DCA held that conducting a juvenile's entire adjudicatory hearing via Zoom over the child's objection, without an evidentiary hearing and without case-specific findings of necessity, violated the juvenile's due process right to confront witnesses. The court reversed the delinquency order and remanded, holding that any remote hearing on remand must be preceded by a hearing on the objection and a case-specific necessity finding. The majority opinion expressly aligns with the Third DCA's J.T.B. and M.D. decisions and distinguishes/disagrees in effect with the Fourth DCA's E.A.C. v. State, creating an acknowledged district split on the standard for remote juvenile proceedings during COVID-19; a vigorous dissent argued juveniles' unenumerated due process confrontation right can be categorically limited without individualized findings.
Key facts
- T.H., a juvenile, was charged with delinquency; the trial court conducted the entire adjudicatory hearing via Zoom over T.H.'s objection without holding a hearing on the objection or making case-specific findings of necessity.
- The trial court relied on generalized pandemic conditions and administrative orders to justify remote proceedings, even though the circuit was conducting in-person jury trials at the time.
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Why it matters
This opinion is significant because it establishes a clear procedural rule for Florida juvenile adjudicatory hearings conducted remotely: courts must hold a hearing on any objection and make case-specific findings of… — full analysis with a trial
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