In re Michael C.

The Rhode Island Department of Children and Their Families (DCF) filed a custody petition alleging that 13-year-old Michael C.'s adoptive father, John, had sexually abused him. John denied the abuse but admitted he would physically harm Michael if Michael became violent toward his mother over her disbelief of the allegation. When it came time for Michael to testify, his guardian ad litem reported that Michael was extremely anxious about testifying in open court, so the trial judge questioned Michael in camera using written questions submitted by the parties. The trial court found Michael had been abused and neglected, granted DCF temporary custody, and restrained John from contact. Michael's parents appealed, arguing they had a constitutional right to confront Michael in open court.