State v. Marcelino B. Baeza, 161 Idaho 38

Defendant Marcelino Baeza was indicted for lewd conduct with his then-five-year-old niece, J.C.; jury convicted him on one count and acquitted on the other; sentence: 20 years, 10 fixed.
The State moved to present the child’s testimony by alternative means, citing risk of serious emotional trauma and PTSD diagnosis from a licensed counselor.
The district court, after hearings, found by clear and convincing evidence that face-to-face confrontation would substantially impair the child’s ability to communicate and authorized alternative testimony under I.C. §§ 9-1805–9-1807.
Trial procedure: child testified via two-way closed‑circuit television; camera positioned so child would not see defendant; court twice instructed jury not to give different weight to testimony because of child‑friendly procedures.
Defendant objected that closed‑circuit testimony violated his due process right to a fair trial, the presumption of innocence (and raised Confrontation Clause concerns), and that the court failed to adequately weigh the statutory factors in I.C. § 9-1806.
Supreme Court of Idaho reviewed de novo and affirmed the conviction, holding (1) use of closed‑circuit TV was not inherently prejudicial and, if any prejudice existed, was justified by the State’s compelling interest in protecting a child witness and (2) the court adequately considered § 9-1806 factors.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Baeza)	Held
Whether closed‑circuit testimony violated due process/presumption of innocence (and implicated Confrontation Clause concerns)	Alternative testimony was necessary to prevent serious trauma to a child witness; procedures were child‑friendly and accompanied by jury instructions	Closed‑circuit testimony signaled to jury that defendant was dangerous or specially perceived by court, undermining presumption of innocence and fair trial	Not inherently prejudicial; jury instructions and child‑focused context negated inference of defendant’s dangerousness; any remote risk justified by compelling state interest in protecting child witnesses
Whether the district court failed to adequately consider the relative rights/interests required by I.C. § 9-1806	Court stated it considered the statutory factors and explicitly balanced defendant’s interests against the child’s welfare	Court did not make explicit findings on presumption of innocence and thus failed to discharge statutory obligation to weigh parties’ rights	No merit; statute does not require written findings on each factor and the record shows the court considered § 9-1806; § 9-1807(1) findings were not challenged

Estelle v. Williams, 425 U.S. 501 (recognition that presumption of innocence is core to fair trial analysis)
Holbrook v. Flynn, 475 U.S. 560 (practices that may undermine presumption of innocence require close scrutiny; case‑by‑case approach)
Maryland v. Craig, 497 U.S. 836 (state’s compelling interest in protecting minor sex‑crime victims can justify alternative testimony methods)
Illinois v. Allen, 397 U.S. 337 (extreme restraints on defendant may be permissible in certain circumstances despite prejudice concerns)
Taylor v. Kentucky, 436 U.S. 478 (defendant entitled to have guilt determined solely on evidence, not extraneous circumstances)
Ohio v. Roberts, 448 U.S. 56 (discusses Confrontation Clause reliability concerns; later abrogated in part by Crawford)
Crawford v. Washington, 541 U.S. 36 (revises Confrontation Clause analysis emphasizing face‑to‑face and testimonial statements)
Poole v. Davis, 153 Idaho 604 (trial courts need consider statutory factors but need not make specific written findings on each factor)