Villarreal v. Texas · ¶21

During a normal trial recess—one that does not interrupt the defendant's testimony—no such infuence is threatened and the Constitution plainly protects a defendant's right to access his counsel without judicial interference. But during a midtestimony recess (when the defendant not only enjoys the Sixth Amendment's protection but also bears a witness's burdens), it is less clear whether and to what extent the Sixth Amendment permits judge-imposed restrictions on the defendant's access to counsel.

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