State v. Slota
Annotate this CaseAfter a jury trial, Defendant was convicted of first-degree rape and sexual contact involving a child. During the trial, the trial judge, on his own initiative, and without a preclosure hearing, closed the courtroom during the victim’s testimony. The jury found Defendant guilty of both charges. After trial, the State moved to supplement the record with facts and reasons for the closure. Defendant moved for a new trial based on the closure. The circuit court granted the State’s motion and denied Defendant’s motion for a new trial. Following a hearing, the court entered findings of fact and conclusions of law supporting closure. The Supreme Court affirmed, holding (1) the circuit court’s error in not having a preclosure hearing to determine whether closure was justified did not require a new trial; and (2) the circuit court made adequate findings demonstrating an overriding interest that was no broader than necessary, considering the alternatives, for courtroom closure during the victim’s testimony.
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