People of Michigan v. Donald Wayne Davis Jr

Summary

The Michigan Supreme Court held that the trial court violated Davis's constitutional right to a public trial by excluding nearly all observers for most of the trial after a benign interaction between an observer and a juror. Although defense counsel failed to object, the failure constituted forfeiture rather than waiver, and the courtroom closure was plain structural error requiring reversal. The Court held that forfeited structural error necessarily affects substantial rights and presumptively satisfies the final plain-error requirement, and the prosecution did not rebut that presumption. Justice Zahra, concurring in the result only, would have affirmed relief under the existing plain-error framework without adopting the majority's new burden-shifting rule.