The State of Washington v. Joseph Bone-Club

Summary

The court held that a defendant's public-trial right extends to a pretrial suppression hearing and that any closure requires the trial court to apply the five-part closure test. Because the trial court summarily cleared the courtroom without considering the competing interests, alternatives, or the scope of closure, it violated the defendant's constitutional right. The court reversed and remanded for a new trial, holding that prejudice is presumed from the violation.