Washington v. Lormor
Annotate this CaseAt issue in this case was whether the removal of a person from the courtroom during trial was a "closure" in violation of the right to a public trial and whether such a "closure" could be considered too trivial as to implicate a defendant's constitutional rights. Defendant Dean Lormor was arrested following a domestic disturbance. During his jail intake, a small bag of methamphetamine was found in his pants pocket. Defendant's daughter, who was four days shy of her fourth birthday, was excluded from the courtroom before trial. The daughter, who was terminally ill, was confined to a wheelchair and required a ventilator to breathe. Before trial, the prosecutor brought the matter up, because Defendant had either talked to or near one of the jurors regarding his daughter. The prosecutor requested that Defendant be precluded from discussing his daughter and her condition. Counsel and and Defendant acquiesced, but Defendant had concerns about eventual sentencing because he hoped to accompany his daughter to Disneyland with the Make-a-Wish Foundation. Defendant was eventually convicted on the possession charge and sentenced to 24 months. He was allowed to go to Disneyland with his daughter before serving his sentence. On appeal Defendant argued that the trial court violated his right to a public trial by excluding his daughter from trial. Additionally, Defendant argued he received ineffective assistance of counsel because his attorney failed to object to the exclusion as a cautionary measure. The appellate court determined that the exclusion was a "closure" but that the trial court's actions did not implicate Defendant's constitutional rights. The Supreme Court held that the exclusion of one person is not a closure that violates a Defendant's right to a public trial, but instead is an aspect of the court's power to control the proceedings. Under the facts of this case, the Court found that the trial court's removal of the young daughter was not an abuse of discretion. Accordingly the Court affirmed the trial court's conviction.
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