State v. Martell
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The Supreme Court affirmed the judgment of the district court convicting Defendant for theft of property exceeding $1,500 in value, holding that the district court committed harmless error in allowing a State witness to appear by two-way video at trial.
Before trial, the State moved the district court to allow the witness to testify by two-way video, arguing that transporting a witness, whose testimony was expected to last only several minutes, almost 500 miles would be overly burdensome and costly. The district court granted the motion. On appeal, Defendant argued that the district court violated his right to confront witnesses against him by allowing the witness to appear by two-way video at trial. The Supreme Court affirmed, holding (1) because the court made no finding establishing an important public policy reason for the video testimony apart from judicial economy, allowing the witness to testify by video violated Defendant's constitutional right to confrontation; but (2) the State met its burden to show that the error was harmless.
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