Taylor v. Dayton, No. 19-2064 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's denial of habeas relief to petitioner, who was convicted of one count of first degree murder and two counts of attempted first degree murder. In this case, the Minnesota Supreme Court issued a list of basic rules for spectators at trial and required spectators to show photographic identification before being allowed entry into the courtroom. On direct appeal, the Minnesota Supreme Court rejected petitioner's argument that the identification requirement violated his Sixth Amendment public right to trial.
The court held that petitioner failed to demonstrate that the Minnesota Supreme Court's decision -- that no closure occurred because there was no evidence that the requirement was enforced -- is both contrary to and an unreasonable application of Waller v. Georgia, 467 U.S. 39 (1984), and Presley v. Georgia, 558 U.S. 209 (2010) (per curiam). Finally, the court declined to exercise its discretion by expanding the certificate of appealability.
Court Description: [Kobes, Author, with Gruender and Wollman, Circuit Judges] Prisoner case - Habeas. The Minnesota courts' determinations that the trial court's rules for entry to Taylor's trial were not enforced, that no closure of the trial occurred, and that Taylor's right to a public trial was not violated were not contrary to or an unreasonable application of Supreme Court precedent.
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