Craig standard in Missouri

2022See, e.g., Carter, 907 F.3d at 1206 ("We now make clear that a defendant's right to physically confront an adverse witness (whether child or adult) cannot be compromised by permitting the witness to testify by video (whether one-way or two-way) unless Craig's standard is satisfied.").

2022See, e.g., Carter, 907 F.3d at 1206 ("We now make clear that a defendant's right to physically confront an adverse witness (whether child or adult) cannot be compromised by permitting the witness to testify by video (whether one-way or two-way) unless Craig's standard is satisfied.").

2022The reliability portion of Craig's test is met by a "combined effect of these elements of confrontation—physical presence, oath, cross-examination, and observation of demeanor by the trier of fact." Craig, 497 U.S. at 846 .

2022The Roberts reliability balancing test was the basis for Craig's rule to allow important public policy considerations to override face-to-face confrontation only when it is necessary and the testimony is reliable enough. 497 U.S. at 850 .

2023See Coffer v. Wasson-Hunt, 281 S.W.3d 308, 311 (Mo. banc 2009) (citing Rule 81.05(a)(2)(A), Rule 81.05(b)).

2022See Comacho, 960 N.W.2d at 756 (A witness was allowed to testify via two-way video to translate portions of telephone calls because it "was not testimony in which an assessment of credibility was as vital or as nuanced as it would be for testimony by the victim of the crime charged or by an eyewitness" and the jury could "listen to the calls and determine whether [the witness's] translations appeared reliable in context.").

2021See, e.g., Carter, 907 F.3d at 1208 (“a criminal defendant’s constitutional rights cannot be neglected merely to avoid added expense or inconvenience”); Yates, 438 F.3d at 1316 (requiring district court to make “case- specific findings of fact that would support a conclusion that this case is different from any other criminal prosecution in which the Government would find it convenient to present testimony by two-way video conference.”); Mercier, 479 P.3d at 976 (finding that Craig’s “necessity” prong was unsatisfied where the State argued that “the use of the two-way video was permissible bec

2021See, e.g., Carter, 907 F.3d at 1208 (“a criminal defendant’s constitutional rights cannot be neglected merely to avoid added expense or inconvenience”); Yates, 438 F.3d at 1316 (requiring district court to make “case- specific findings of fact that would support a conclusion that this case is different from any other criminal prosecution in which the Government would find it convenient to present testimony by two-way video conference.”); Mercier, 479 P.3d at 976 (finding that Craig’s “necessity” prong was unsatisfied where the State argued that “the use of the two-way video was permissible bec

2021App. Div. 2013) (finding that the standards enunciated in Craig were met and further finding that the use of the “two-way closed circuit television” allowed the witness and the defendant to see each other during the witness’s testimony, unlike in Craig); People v. Wrotten, 923 N.E.2d 1099, 1102 (N.Y. 2009) (court “assum[ed] without deciding that two-way video does not always satisfy the Confrontation Clause’s ‘face-to-face meeting’ requirement” citing the Craig necessity standard, but cross referenced Gigante as holding that the use of “two-way video ‘preserved the face-to-face confrontation’”

2021App. Div. 2013) (finding that the standards enunciated in Craig were met and further finding that the use of the “two-way closed circuit television” allowed the witness and the defendant to see each other during the witness’s testimony, unlike in Craig); People v. Wrotten, 923 N.E.2d 1099, 1102 (N.Y. 2009) (court “assum[ed] without deciding that two-way video does not always satisfy the Confrontation Clause’s ‘face-to-face meeting’ requirement” citing the Craig necessity standard, but cross referenced Gigante as holding that the use of “two-way video ‘preserved the face-to-face confrontation’”

2021See U.S. v. Abu Ali, 528 F.3d 210, 242 (4th Cir. 2008) (finding no Confrontation Clause violation under the Craig analysis, but noting that the “two-way link” used in that case “meant that the witnesses were able to view the defendant as they testified, a protection not present in Craig”); People v. Beltran, 110 A.D.3d 153, 162 (N.Y.

2021See U.S. v. Abu Ali, 528 F.3d 210, 242 (4th Cir. 2008) (finding no Confrontation Clause violation under the Craig analysis, but noting that the “two-way link” used in that case “meant that the witnesses were able to view the defendant as they testified, a protection not present in Craig”); People v. Beltran, 110 A.D.3d 153, 162 (N.Y.

2021See, e.g., Carter, 907 F.3d at 1208 (“a criminal defendant’s constitutional rights cannot be neglected merely to avoid added expense or inconvenience”); Yates, 438 F.3d at 1316 (requiring district court to make “case- specific findings of fact that would support a conclusion that this case is different from any other criminal prosecution in which the Government would find it convenient to present testimony by two-way video conference.”); Mercier, 479 P.3d at 976 (finding that Craig’s “necessity” prong was unsatisfied where the State argued that “the use of the two-way video was permissible bec

2021See, e.g., Carter, 907 F.3d at 1208 (“a criminal defendant’s constitutional rights cannot be neglected merely to avoid added expense or inconvenience”); Yates, 438 F.3d at 1316 (requiring district court to make “case- specific findings of fact that would support a conclusion that this case is different from any other criminal prosecution in which the Government would find it convenient to present testimony by two-way video conference.”); Mercier, 479 P.3d at 976 (finding that Craig’s “necessity” prong was unsatisfied where the State argued that “the use of the two-way video was permissible bec

2021See U.S. v. Abu Ali, 528 F.3d 210, 242 (4th Cir. 2008) (finding no Confrontation Clause violation under the Craig analysis, but noting that the “two-way link” used in that case “meant that the witnesses were able to view the defendant as they testified, a protection not present in Craig”); People v. Beltran, 110 A.D.3d 153, 162 (N.Y.

2021See U.S. v. Abu Ali, 528 F.3d 210, 242 (4th Cir. 2008) (finding no Confrontation Clause violation under the Craig analysis, but noting that the “two-way link” used in that case “meant that the witnesses were able to view the defendant as they testified, a protection not present in Craig”); People v. Beltran, 110 A.D.3d 153, 162 (N.Y.

2011See In re Marriage of Wardlaw, 809 S.W.2d 470, 472 (Mo.App.1991). 2 .