State v. Barrett

Summary

The court held that the district court violated Barrett’s constitutional right to a public trial by closing the courtroom while the jury reviewed a recorded interview during deliberations. The court concluded that reviewing requested evidence in court is not itself jury deliberation requiring closure, and that the district court plainly misapplied the governing open-court and closure requirements. Because the error was structural and seriously affected the fairness, integrity, and public reputation of the proceedings, the judgment was reversed and a new trial ordered.