State v. Bone-Club

Summary

The court held that a trial court violates a defendant's constitutional public-trial right when it fully closes a pretrial suppression hearing without applying the required five-factor closure analysis. The trial court's summary closure, failure to provide a meaningful opportunity to object, and lack of specific findings could not be cured by appellate review. The court reversed and remanded for a new trial because prejudice is presumed and a new suppression hearing alone might not account for differences in testimony caused by the prior closure.