## Facts

- John Avery Coy was charged in Iowa with sexually assaulting two 13-year-old girls.
- At Coy’s jury trial, the State invoked an Iowa statute aimed at protecting child sexual-abuse victims and requested a large screen be placed between Coy and the testifying girls.
- The screen prevented the girls from seeing Coy while testifying; Coy could see them only dimly and could hear them; the judge, jury, and counsel could see and hear the girls.
- Coy objected, arguing the screen violated his Sixth Amendment right to confront the witnesses and also prejudiced him by implying guilt.
- The trial court overruled the objections, the girls testified behind the screen, and Coy was convicted of two counts of lascivious acts with a child.
- The Iowa Supreme Court affirmed, concluding the procedure complied with the Confrontation Clause.

## Issues

1. Whether using a screen that prevents child witnesses from seeing the defendant while they testify violates the Sixth Amendment right “to be confronted with the witnesses against” the accused.
2. If the Confrontation Clause was violated, whether the error is subject to harmless-error review and, if so, whether it was harmless beyond a reasonable doubt.

## Decision

- The U.S. Supreme Court reversed the judgment affirming Coy’s convictions and remanded.
- The Court held that the screen procedure denied Coy the Sixth Amendment’s face-to-face confrontation with the witnesses against him.
- The Court rejected reliance on a generalized statutory presumption of trauma without case-specific findings justifying the departure from face-to-face confrontation.
- The Court held the violation is subject to harmless-error analysis under the “harmless beyond a reasonable doubt” standard, but remanded because the Iowa Supreme Court had not addressed harmlessness.

## Legal Principles

- The Confrontation Clause guarantees a defendant a face-to-face encounter with testifying witnesses as a central component of confrontation.
- A State may not displace face-to-face confrontation based solely on generalized legislative assumptions; any departure requires more than a categorical presumption and, at minimum, individualized justification or a historically recognized exception.
- Denial of face-to-face confrontation is not automatically reversible; it is reviewed for harmlessness beyond a reasonable doubt.

## Conclusion

Because the screen prevented the child witnesses from seeing Coy while testifying and the procedure rested on a generalized statutory policy rather than individualized findings, the Court found a Sixth Amendment violation, reversed, and remanded for the state courts to determine whether the error was harmless beyond a reasonable doubt.


Coy v. Iowa, 487 U.S. 1012 (1988)