T.T.W. v. State
The Third DCA reversed a juvenile delinquency adjudication because the trial court permitted a police officer witness to testify via Zoom without making any case-specific finding of necessity, violating T.T.W.'s confrontation rights. Relying on its recent decision in J.T.B. v. State, the court held this amounted to a due process violation and remanded for a new adjudicatory hearing, noting that remote testimony may still be used if the trial court first holds a hearing and makes the required case-specific necessity finding.
Key facts
- T.T.W., a juvenile, was charged with delinquency, and a police officer witness testified via Zoom at the adjudicatory hearing over defense objection.
- The trial court did not make any case-specific finding of necessity before permitting the remote testimony.
- +2 more key facts with a free trial
Why it matters
This case reinforces the Third DCA's recent J.T.B. precedent requiring case-specific necessity findings before allowing remote witness testimony in juvenile delinquency adjudications, extending that rule to a mixed… — full analysis with a trial
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