Kentel Myrone Weaver, Petitioner v. Massachusetts.

Summary

The Supreme Court held that a structural error—here, closure of the courtroom to the public during two days of jury selection—does not entitle a defendant to automatic relief when it is raised for the first time in an ineffective-assistance-of-counsel claim rather than preserved and presented on direct review; the defendant must instead make a Strickland prejudice showing, either a reasonable probability of a different outcome or, as the Court assumed for analytical purposes, a demonstration that the violation rendered the trial fundamentally unfair. Public-trial violations are structural not because every closure makes a trial fundamentally unfair but because closure's effects are hard to measure and the right serves the public and press as well as the accused; raising the closure late also deprives the trial court of any chance to cure it and heightens finality concerns. Kentel Weaver, whose mother and her minister were turned away during voir dire, showed neither form of prejudice—his trial was not secret, the closure was limited to jury selection, and nothing suggests juror deceit or misconduct—so the Massachusetts Supreme Judicial Court's denial of a new trial was affirmed.