Tonisha Mitchell v. State of Arkansas

Summary

The court held that closing the courtroom during a prosecution witness's testimony violated Mitchell's constitutional right to a public trial. The trial court relied only on an unsubstantiated allegation of possible witness intimidation, developed no evidentiary record, considered no alternatives, and made no adequate findings to support closure; no showing of actual prejudice was required. The court reversed Mitchell's conviction and remanded for a new trial.