Williams v. Texas (original by judge slaughter)
Annotate this CasePolice organized a “controlled buy” of drugs wherein a confidential informant purchased crack cocaine from Appellant April Williams. Based on her sale of drugs to the informant, Appellant was indicted for delivery of a controlled substance, Penalty Group 1, in an amount of four grams or more but less than 200 grams. At Appellant’s jury trial, the State first called Detective Jaime Diaz as a witness. Following Diaz’s testimony, the State planned to call the informant as a witness. But before the informant, the State requested that a spectator, Appellant’s brother Jerry Williams, be temporarily excluded from the courtroom during the testimony. The State contended that it had “credible and reliable information” that Williams’s presence would intimidate the informant, which would affect his testimony. The State also provided caselaw to the court “supporting closing the courtroom because of the intimidation factor.” To minimize the effects of the closure, the State offered to set up a live video feed in another room of the courthouse so that Williams could watch the informant's testimony in real time. The issue this case presented for the Texas Court of Criminal Appeals was whether the temporary physical exclusion from a courtroom of a defendant’s family member for the testimony of one witness at trial violate the Sixth Amendment right to a public trial when the excluded individual was virtually included by permitting him to observe the witness’s testimony via a live video feed from a neighboring courtroom. Under the specific facts of this case, the Court held it did not, but cautioned that trial courts should rarely exclude any member of the public from a courtroom during criminal case proceedings: "under the narrow circumstances presented here...even assuming that the trial court’s actions resulted in a partial closure of the courtroom, any such closure was so trivial or de minimis that it did not infringe on the values served by the Sixth Amendment."
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