State v. SeatonAnnotate this Case
Circuit Judge Richard J. Nuss presided over two jury trials, State v. Pinno and State v. Seaton. In both voir dire proceedings, Judge Nuss asked the public to leave the courtroom to make room for large jury panels. Defendants were subsequently convicted after jury trials open to the public. Defendants filed postconviction motions, alleging violations to their right to a public trial. Judge Nuss denied all postconviction motions. The Supreme Court affirmed, holding (1) the Sixth Amendment right to a public trial extends to voir dire, and a judge’s decision to close or limit public access to a courtroom in a criminal case requires the analysis set forth in Waller v. Georgia; (2) the Sixth Amendment right to a public trial may be asserted by the defendant at any time during a trial; (3) because neither Defendant in this case objected to the alleged courtroom closure, Defendants both forfeited their rights to a public trial; (4) defendants must demonstrate prejudice to prove ineffective assistance of counsel when counsel fails to object to the closure of the courtroom, and Defendants in this case failed to prove that their counsel was ineffective; and (5) Seaton was not denied his right to an impartial judge.