California, United States of America
The following excerpt is from People v. Grattan, D065292 (Cal. App. 2016):
"[A]ppellate courts should independently review a trial court's determination that the prosecution's failed efforts to locate an absent witness are sufficient to justify an exception to the defendant's constitutionally guaranteed right of confrontation at trial." (People v. Cromer (2001) 24 Cal.4th 889, 901.)
b. Application
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