State v. Rolfe
Annotate this CaseAfter a jury trial, Defendant was convicted of three counts of first-degree rape of a minor and twelve counts of possessing, manufacturing, or distributing child pornography. During the trial the trial court closed the courtroom to members of the general public during the victim’s testimony. On appeal, the Supreme Court concluded that the trial court improperly closed Defendant’s trial to the public without making sufficient findings regarding the closure. The Court remanded the case and instructed the court to enter supplemental findings regarding the closure. On remand, the trial court held a supplemental hearing and found that substantial reason existed for closing the courtroom. Defendant appealed, contending that remanding for supplemental findings was an inappropriate remedy. The trial court denied the motion. The Supreme Court affirmed, holding (1) the remedy ordered by the Court in Rolfe I was appropriate to cure the constitutional violation alleged; and (2) the trial court did not improperly close Defendant’s trial in violation of his Sixth Amendment right to a public trial.
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