The Sixth Amendment’s Confrontation Clause provides to a criminal defendant the right to confront and cross-examine adverse witnesses.  The Supreme Court has repeatedly recognized the importance of cross-examination.  As the Court stated in Coy v. Iowa, 487 U.S. 1012, 1019 (1988), “[i]t is always more difficult to tell a lie about a person ‘to his face’ than ‘behind his back.'”

Although defendants generally enjoy a right to face-to-face confrontation of witnesses, this right is not absolute.  Unique circumstances in a case may require the court to take alternative measures to ensure the essence of the defendant’s right of confrontation.

 
How Appealing had this interesting post : “[W]e have occasion here to address an issue of first impression in this circuit, namely whether a witness’s testimony in disguise at trial violates the Confrontation Clause of the Sixth Amendment to the United States Constitution.” So states an opinion that a three-judge panel of the U.S. Court of Appeals for the Ninth Circuit issued today.

The unanimous panel proceeds to hold “that in this case, the disguise in the form of a wig and mustache did not violate the Confrontation Clause.”