The Supreme Court of Pennsylvania held that a statute allowing children to testify outside the physical presence of a defendant by means of videotape or closed circuit television violates the defendant's constitutional right to confront witnesses face-to-face. The court further held that Article I, section 9 of the Pennsylvania Constitution requires a face-to-face confrontation between a defendant and a witness, and allows exceptions only when the defendant has previously had the opportunity to physically confront and cross-examine the witness.
Commonwealth v. Louden, 638 A.2d 953 (Pa. 1994).
Michael L. Bell,
Constitutional Law - Criminal Procedure - Child Testimony via Videotape or Closed Circuit Television - Defendant's Right to Confront Witnesses,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol33/iss2/9