N.J. Stat. » Title 2A — ADMINISTRATION OF CIVIL AND CRIMINAL JUSTICE
New Jersey Statutes

N.J. Stat. § 2A:84A-32.4 (2026)

Prosecutions, certain actions, closed circuit testimony

✓ current as of May 2026
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1. a. (1) In prosecutions for aggravated sexual assault, sexual assault, aggravated criminal sexual contact, criminal sexual contact, human trafficking involving sexual activity, a crime involving domestic violence as defined in section 3 of P.L.1991, c.261 (C.2C:25-19), endangering the welfare of a child pursuant to N.J.S.2C:24-4, abuse or neglect of a child pursuant to R.S.9:6-3, or in any action alleging an abused or neglected child under P.L.1974, c.119 (C.9:6-8.21 et seq.), the court may, on motion and after conducting a hearing in camera, order the taking of the testimony of a victim or witness on closed circuit television at the trial, out of the view of the jury, defendant, or spectators upon making findings as provided in subsection b. of this section.

(2) In granting such an order, the court shall assure that:

(a) the victim or witness will testify under oath;

(b) the victim or witness will submit to cross-examination by the defendant's attorney; and

(c) the defendant, jury, and judge will be permitted to observe the demeanor of the victim or witness when making testimonial statements using closed circuit television.

b. An order under this section may be made only if the court determines by clear and convincing evidence that there is a substantial likelihood that the victim or witness would suffer severe emotional or mental distress if required to testify in the presence of spectators, the defendant, the jury, or all of them. The order shall be specific as to whether the victim or witness will testify outside the presence of spectators, the defendant, the jury, or all of them and shall be based on specific findings relating to the impact of the presence of each.

c. A motion seeking closed circuit testimony under subsection a. of this section may be filed by:

(1) The victim or witness or, in the case of a victim or witness who is under the age of 18, the victim's or witness's attorney, parent or legal guardian;

(2) The prosecutor; or

(3) The defendant or the defendant's counsel.

d. The defendant's counsel shall be present in the same room as the victim or witness at the taking of testimony on closed circuit television. The defendant and the defendant's attorney shall be able to confer privately with each other during the testimony by a separate audio system.

e. If testimony is taken on closed circuit television pursuant to the provisions of this section, the video portion of the testimony shall not be recorded and shall not constitute part of the record on appeal. All audio transmissions, except private conversations between the defendant and the defendant's attorney, shall be recorded and thereafter shall be subject to the following provisions:

(1) If the victim or witness is 18 years of age or older at the time of the court proceedings, any recording of the audio portion of the closed circuit testimony shall constitute part of the record on appeal, unless the court orders otherwise for good cause shown upon motion of the parties.

(2) If the victim or witness is under the age of 18 at the time of the court proceedings, any recording of the audio portion of the closed circuit testimony shall not constitute part of the record on appeal and shall be deemed confidential and not available to the public, unless the court orders otherwise for good cause shown upon motion of the parties. In making the determination regarding the availability of the audio portion of the testimony, the court shall consider potential trauma or stigma to the victim or witness. A transcript of the audio portion of the closed circuit testimony shall constitute part of the record on appeal, subject to any personal identification safeguards contained in section 1 of P.L.1989, c.336 (C.2A:82-46).

f. For purposes of this section, "closed circuit television" means any closed-circuit, videoconferencing or other audio-visual electronic technology capable of producing a simultaneous, one-way broadcast from a victim or witness to a defendant in a separate physical location. The technology shall allow for the live observation of the victim or witness by the defendant, jury, and judge during the course of testimony or cross-examination, while excluding a victim or witness from directly hearing or viewing the defendant during the proceedings.

Notes of Decisions
Cited in 14 cases (7 in the last 5 years), 1987–2026 · leading case: New Jersey Div. of Child Prot. & Permanency v. C.W. in the Matter of I.N.W., 87 A.3d 245 (N.J. Super. Ct. App. Div. 2014).
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New Jersey Div. of Child Prot. & Permanency v. C.W. in the Matter of I.N.W., 87 A.3d 245 (N.J. Super. Ct. App. Div. 2014). · cites it 5× “2(c), when a defendant objects to utilizing an alternative to the child's in-court testimony, the judge must adhere to the statutory procedures outlined in N.J.S.A. 2A:84A-32.4, prior to allowing in camera testimony of a child-witness.”
Miller v. State, 517 N.E.2d 64 (Ind. 1987). “); N.J.Stat.Ann. § 2A:84A-32.4 (West 1987 Supp.”
Craig v. State, 560 A.2d 1120 (Md. 1989). “Laws § 278:16D(b)(1) (1986); N.J.Stat.Ann. § 2A:84A-32.4(b) (Supp.1988), our cases suggest that the strictures of the *561 Confrontation Clause may give way to the compelling state interest of protecting child witnesses.”
State v. McCutcheon, 560 A.2d 1303 (N.J. Super. Ct. App. Div. 1988). · cites it 4× “THE CONSTITUTIONALITY OF N.J.S.A. 2A:84A-32.4 The New Jersey statute involved, provides in pertinent part that: a.”
Dcpp Vs. S.S. & R.b., in the Matter of B.B. (fn-12-0263-17, Middlesex Cnty. & Statewide) (record Impounded) (N.J. Super. Ct. App. Div. 2021). · cites it 6× “A-0319-19T2 2 was not conducted in accordance with N.J.S.A. 2A:84A-32.4 and violated his due process rights.”
State of New Jersey v. R.G.W. (N.J. Super. Ct. App. Div. 2025). · cites it 5× “to another testimonial examination, which was contrary to the purpose of N.J.S.A. 2A:84A-32.4, the Victim's Rights Amendment to the New Jersey Constitution, art.”
Dcpp v. E.G. & J.f., in the Matter of L.B. (fn-04-0219-20, Camden Cnty. & Statewide) (record Impounded) (N.J. Super. Ct. App. Div. 2022). · cites it 4× “" A-3617-19 7 N.J.S.A. 2A:84A-32.4 AND N.J.S.A. 2A:61-B1 THEREBY VIOLATING [DEFENDANT'S] RIGHT OF CONFRONTATION A.”
New Jersey Div. of Child Prot. & Permanency v. C.W. in the Matter of I.N.W. (N.J. Super. Ct. App. Div. 2014). · cites it 5× “21, when a defendant objects to utilizing an alternative to the child's in-court testimony, the judge must adhere to the statutory procedures outlined in N.J.S.A. 2A:84A-32.4, prior to allowing in camera testimony of a child-witness.”
Dcpp Vs. L.g., in the Matter of N.G. (fn-12-0296-12, Middlesex Cnty. & Statewide) (record Impounded) (N.J. Super. Ct. App. Div. 2018). · cites it 2× “She also contends the court failed to adhere to the procedures outlined in N.J.S.A. 2A:84A-32.4, specifically that "there is a substantial likelihood .”
Dcpp Vs. S.C. & D.r., in the Matter of S.c., Jr. (fn-01-0389-16, Atl. Cnty. & Statewide) (record Impounded) (Consol.) (N.J. Super. Ct. App. Div. 2019). “2014), and N.J.S.A. 2A:84A-32.4. D.R. consented to the interview, and the court gave her the opportunity to pose questions for the court to ask.”
State of New Jersey Vs. E.r.-l. (17-09-0638, Hudson Cnty. & Statewide) (record Impounded) (N.J. Super. Ct. App. Div. 2021). “The court also granted the State's application to allow Anna to testify at trial by closed circuit television (CCTV) pursuant to N.J.S.A. 2A:84A-32.4 (allowing CCTV testimony at trial "if the court determines by clear and convincing evidence that there is a substantial…”
Dcpp v. A.H. & J.M., in the Matter of C.M. & L.M. (N.J. Super. Ct. App. Div. 2025). “could testify in camera by clear and convincing evidence under N.J.S.A. 2A:84A-32.4. Referencing the therapist's report, the court reasoned to do otherwise "would be potential trauma" to C.”
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N.J. Stat. § 2A:84A-32.4(a): 2 cases
Dcpp Vs. S.S. & R.b., in the Matter of B.B. (fn-12-0263-17, Middlesex Cnty. & Statewide) (record Impounded) (N.J. Super. Ct. App. Div. 2021). “A-0319-19T2 2 was not conducted in accordance with N.J.S.A. 2A:84A-32.4 and violated his due process rights.”
Dcpp v. E.G. & J.f., in the Matter of L.B. (fn-04-0219-20, Camden Cnty. & Statewide) (record Impounded) (N.J. Super. Ct. App. Div. 2022). “" A-3617-19 7 N.J.S.A. 2A:84A-32.4 AND N.J.S.A. 2A:61-B1 THEREBY VIOLATING [DEFENDANT'S] RIGHT OF CONFRONTATION A.”
N.J. Stat. § 2A:84A-32.4(a)(1): 1 case
State of New Jersey v. R.G.W. (N.J. Super. Ct. App. Div. 2025). “to another testimonial examination, which was contrary to the purpose of N.J.S.A. 2A:84A-32.4, the Victim's Rights Amendment to the New Jersey Constitution, art.”
N.J. Stat. § 2A:84A-32.4(a)(2): 1 case
State of New Jersey v. R.G.W. (N.J. Super. Ct. App. Div. 2025). “to another testimonial examination, which was contrary to the purpose of N.J.S.A. 2A:84A-32.4, the Victim's Rights Amendment to the New Jersey Constitution, art.”
N.J. Stat. § 2A:84A-32.4(b): 3 cases
Craig v. State, 560 A.2d 1120 (Md. 1989). “Laws § 278:16D(b)(1) (1986); N.J.Stat.Ann. § 2A:84A-32.4(b) (Supp.1988), our cases suggest that the strictures of the *561 Confrontation Clause may give way to the compelling state interest of protecting child witnesses.”
Dcpp v. E.G. & J.f., in the Matter of L.B. (fn-04-0219-20, Camden Cnty. & Statewide) (record Impounded) (N.J. Super. Ct. App. Div. 2022). “" A-3617-19 7 N.J.S.A. 2A:84A-32.4 AND N.J.S.A. 2A:61-B1 THEREBY VIOLATING [DEFENDANT'S] RIGHT OF CONFRONTATION A.”
State of New Jersey v. R.G.W. (N.J. Super. Ct. App. Div. 2025). “to another testimonial examination, which was contrary to the purpose of N.J.S.A. 2A:84A-32.4, the Victim's Rights Amendment to the New Jersey Constitution, art.”
N.J. Stat. § 2A:84A-32.4(d): 1 case
State of New Jersey v. R.G.W. (N.J. Super. Ct. App. Div. 2025). “to another testimonial examination, which was contrary to the purpose of N.J.S.A. 2A:84A-32.4, the Victim's Rights Amendment to the New Jersey Constitution, art.”
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