The "White" Court framed its confrontation clause analysis in terms of ensuring the admission of reliable and probative evidence. In so doing, the majority limited its prior safeguards for criminal defendants' confrontation rights. By restricting the necessity requirement of "Coy" and "Craig" to special in-court procedures, the Court found hearsay that was not subject to cross-examination was more consistent with the goals of the confrontation clause than in-court testimony under child-protective procedures. The limitation of "Roberts'" unavailability requirement to former testimony again reduced the confrontation clause protections available to criminal defendants by imposing fewer requirements on prosecutors seeking to introduce uncross-examined out-of-court statements than testimony that has been subject to some form of cross-examination. The "White" decision will have a significant impact on the confrontation rights of all criminal defendants. The Court did not limit its holding to child sexual abuse cases, but rather announced a broad ruling applicable to all criminal defendants. 251 footnotes