citing Mattox v. United States 156 U.S. 237, 242 (1895). She further identified four primary guarantees embodied in the Confrontation Clause: The right of "personal examination" That a witness will testify under oath That a witness will submit to cross-examination That the jury may observe the demeanor of the witness in making his statement The Court noted that hearsay exceptions demonstrated that no defendant had an absolute right to a face-to-face encounter with adversarial witnesses. While the Maryland exception did not provide face-to-face confrontation, the final three preserved guarantees were present. The State's interest in the physical and psychological well-being of child abuse victims could outweigh the defendant's right to face his accusers in court. Dissent Justice Scalia, in dissent, wrote that he was "persuaded...that the Maryland procedure is virtually constitutional. Since it is not, however, actually constitutional I would affirm the judgment of the Maryland Court of Appeals reversing the judgment of conviction." Subsequent developments The continued validity of Craig was called into question after the Supreme Court case Crawford v. Washington (2004). In Crawford, the Court overruled Ohio v. Roberts (1980), which Craig relied in large part upon. However, Craig remains good law. During the COVID-19 pandemic, federal courts conducting criminal trials, relied upon Craig to have witnesses testify by "Zoom or some other videoconferencing technology." See also List of United States Supreme Court cases, volume 497 List of United States Supreme Court cases Lists of United States Supreme Court cases by volume List of United States Supreme Court cases by the Rehnquist Court References External links United States Supreme Court cases United States Supreme Court cases of the Rehnquist Court Confrontation Clause case law 1990 in United States case law 1990 in Maryland Child sexual abuse in the United States