State v. L. Strommen

Summary

The court held that the trial court violated Strommen’s federal and state confrontation rights by permitting a prosecution expert to testify remotely by two-way video without a case-specific showing that her personal appearance was unavailable or that remote testimony was necessary to advance an important public policy. The court further held that the error was not harmless because the expert’s testimony was highly relevant and potentially influential in a credibility-centered prosecution. The conviction was reversed and the case was remanded for a new trial.