In the case of Maryland v. Craig, 1989, the U.S. Supreme Court ruled in favor of allowing a child witness to testify via one-way closed circuit television in cases involving child abuse. The court held that this procedure did not violate the defendant's Sixth Amendment right to confront witnesses against them if it is necessary to protect a child witness from trauma that would be caused by testifying in front of the defendant. In this particular case, Sandra Ann Craig was accused and convicted for sexually abusing a six-year-old girl under her care at a kindergarten she operated from her home. During trial, due to concerns about potential psychological harm on the minor victim, she testified outside Craig’s presence through closed-circuit TV while being cross-examined by defense counsel with only judge and jury present inside courtroom.

In the dissenting opinion for Maryland v. Craig, Justice Scalia argued that the majority's decision to allow a child witness in a child abuse case to testify via one-way closed circuit television violated the Confrontation Clause of the Sixth Amendment. He contended that this clause guarantees defendants an absolute right to face-to-face confrontation with their accusers during trial, and exceptions should not be made based on psychological harm or trauma potentially caused by such confrontations. Scalia believed that any departure from this principle would undermine centuries of legal tradition and precedent which uphold direct confrontation as essential for ensuring fair trials. He also expressed concern about potential misuse of similar procedures in future cases, arguing it could lead to further erosion of defendants' constitutional rights.