The Supreme Court of Guam issued an opinion in *People of Guam v. Stefan Keanu Camacho* addressing whether a defendant's Sixth Amendment confrontation rights are violated when a key government witness testifies remotely during a murder trial.
Defendant-Appellant Stefan Keanu Camacho challenged the Superior Court of Guam's decision to grant the People's request allowing a government witness to testify remotely at his murder trial. The witness in question is Dr. Jeffrey Nine, Guam's former Medical Examiner who performed the autopsy of the alleged victim in the case.
The case, designated as Supreme Court Case No. CRA25-008 and originating from Superior Court Case No. CF0019-24, was argued and submitted on May 30, 2025, in Hagåtña, Guam. The three-justice panel included Chief Justice Robert J. Torres, Associate Justice F. Philip Carbullido, and Associate Justice Katherine A. Maraman, with Justice Carbullido writing the opinion.
Dr. Nine testified that he currently lives in Ohio and cannot travel to Guam due to the medical conditions affecting his wife and child. This circumstance led the trial court to consider whether remote testimony would be appropriate given the practical impossibility of in-person appearance.
Camacho's appeal centers on his Sixth Amendment right to confront witnesses against him. The Confrontation Clause of the Sixth Amendment guarantees criminal defendants the right to be confronted with the witnesses against them, traditionally understood to require face-to-face confrontation during trial proceedings.
The defendant is represented by Stephen P. Hattori, Public Defender with the Public Defender Service Corporation, based in Sinajana. The People of Guam are represented by Assistant Attorney General Emily L.A. Rees from the Appellate & Writing Division of the Office of the Attorney General in Hagåtña.
The Supreme Court of Guam acknowledged the fundamental importance of confrontation rights, stating that "the right to confrontation must be zealously protected." However, the court also recognized that the Sixth Amendment does not categorically require in-person, face-to-face confrontation in all cases without exception.
The opinion indicates that the trial court applied the correct legal standard when evaluating whether to permit remote testimony. Courts must balance the defendant's confrontation rights against the practical necessities that may make in-person testimony impossible or unduly burdensome.
In this case, the medical examiner's testimony would be crucial evidence in a murder prosecution. Dr. Nine's autopsy findings and expert opinion regarding the cause and manner of death would likely be central to the government's case against Camacho. The loss of this testimony due to the witness's inability to travel could significantly impact the prosecution's ability to prove its case.
The court's analysis focused on the "unique facts on the record" before it. These facts include Dr. Nine's relocation to Ohio and his assertion that family medical circumstances prevent him from traveling to Guam for trial. The court found that under these specific circumstances, Dr. Nine's remote testimony is "necessary to further" important governmental interests.
This decision reflects the evolving approach to confrontation rights in an era where technology enables remote testimony while preserving many aspects of the confrontation right. Modern courts increasingly recognize that video technology can provide meaningful confrontation opportunities while accommodating practical realities that make in-person testimony impossible.
The case highlights the tension between preserving defendants' constitutional rights and ensuring that important evidence can be presented to juries. In murder cases particularly, medical examiner testimony is often essential to establishing key elements of the prosecution's case, including cause of death and other forensic findings.
The Supreme Court of Guam's decision appears to follow precedent from other jurisdictions that have grappled with similar issues. Federal courts and other state supreme courts have generally held that remote testimony may be permissible when specific findings are made regarding necessity and when appropriate safeguards are in place to preserve confrontation values.
The opinion suggests that the court conducted a narrow analysis based on the specific facts presented, rather than establishing a broad rule permitting remote testimony in all cases. This approach reflects judicial recognition that confrontation rights must be evaluated on a case-by-case basis.
For criminal defendants in Guam, this decision establishes that while confrontation rights remain fundamental and must be zealously protected, courts may permit remote testimony under exceptional circumstances when proper legal standards are applied and specific factual findings support such arrangements.
The case demonstrates the ongoing evolution of constitutional criminal procedure as courts adapt traditional doctrines to modern technological capabilities and practical realities facing the justice system.