New Mexico v. Turrietta
Annotate this CaseDefendant Manuel Turrietta argued on appeal to the Supreme Court that his right to a public trial was violated when the district court partially closed the courtroom during the testimony of two confidential informants. Upon review, the Supreme Court concluded that the state did not demonstrate an overriding interest for closing the courtroom, and that the district court failed to adequately assess the possible alternatives to closure, or to make adequate findings to support its decision. A "substantial reason" standard does not meet constitutional muster, and the Court held that courts must apply a "Waller" standard prior to closure. As such, Defendant's Sixth Amendment right to a public trial was violated, and the courtroom closure was unconstitutional. Accordingly, the Court remanded the case for a new trial.
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