In Re Pers. Restraint of Speight (Majority, Concurrence and Dissent)
Annotate this CasePetitioner Ronald Speight filed a timely personal restraint petition, claiming for the first time on collateral review that his right to a public trial under article I, section 22 of the Washington State Constitution, was violated when the trial court decided motions in limine and individually questioned potential jurors in chambers. Consistent with its holding in "In re Personal Restraint of Coggin," the Supreme Court held that a petitioner claiming a public trial right violation for the first time on collateral review must show actual and substantial prejudice. Speight could not show actual and substantial prejudice arising from the closure; therefore, his petition was denied.
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