Alexander v. Georgia
Annotate this CaseStephen Alexander was convicted by jury of sexual offenses against his stepdaughters, both of whom were minors during Alexander’s trial. At trial, the two victims and a child advocate testified in a courtroom that was partially closed to spectators at the direction of the trial court. Alexander sought to challenge the closure of the courtroom solely through a Sixth Amendment claim of ineffective assistance of counsel under Strickland v. Washington, 466 U. S. 668 (1984). The improper closure of a courtroom was considered a “structural” error that results in reversal of a defendant’s conviction on direct appeal if the error was committed over objection. Alexander’s trial counsel did not object. The trial court and the Court of Appeals determined that the proper Strickland analysis required a defendant in this posture to demonstrate actual prejudice to prevail, and rejected Alexander’s claim of ineffective assistance of counsel for failure to show any such prejudice. To this, the Georgia Supreme Court concurred and affirmed the lower courts' decisions.
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