United States Court of Appeals, Second Circuit
New York State Court of Appeals
People v. Dokes, 79 N.Y.2d 656 (1992)
This appeal established the principal that a defendant must be present at all significant stages of the trial. As a result a practice has been instituted in trial courts around the state wherein judges discuss with defendants when it is acceptable for their attorney to approach the bench and discuss matters with the court without their being present (trial counsel only).