Perry v. Leeke

·1989

What the Court Decided

The Court held that a trial court may constitutionally order no contact between a defendant and counsel during a brief daytime recess while the defendant is testifying, distinguishing Geders' overnight recess rule.

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Cited In

Villarreal v. Texas

2025 Term · 24-557

Central to both sides' arguments—Perry upheld a no-contact order during a brief 15-minute recess and drew a constitutional distinction between overnight and brief daytime recesses. The parties disputed Perry's precise holding regarding qualified orders overnight.