Supreme Court of Florida
Anthony Kovaleski v. State of Florida
October 25, 201237 Fla. L. Weekly Supp. 661
Summary
The Florida Supreme Court held that a partial courtroom closure under Florida Statute §918.16(2) satisfies the Waller test and does not violate the Sixth Amendment right to a public trial. It approved the Fourth District Court of Appeal’s decision affirming Kovaleski’s convictions, but on different reasoning, and disapproved the Third District’s Alonso decision to the extent it conflicted. The Court also declined to address a purported conflict with Jaggers because the Pantoja decision resolves that issue.