In T.H. v. State, the Second District Court of Appeal, examined the right to in-person confrontation and the public health need to avoid or limit the spread of COVID-19 in the context of a bench trial of a juvenile charged with carrying a concealed firearm.
The Second DCA held that the trial court erred in ruling that the adjudicatory hearing would proceed via Zoom without allowing T.H. a hearing on his objection and without making a case-specific finding of necessity to limit confrontation rights.
The Court stressed that the determination was limited to the narrow facts presented in this case.
You can read the opinion here: https://www.2dca.org/content/download/832687/opinion/203217_DC13_03182022_082201_i.pdf