In the Matter of the Personal Restraint of Christopher A. Orange

Summary

The court granted Orange’s personal restraint petition and remanded for a new trial because the trial court closed voir dire to family members, the press, and all other spectators without applying the required closure procedures, and appellate counsel’s failure to raise the issue constituted ineffective assistance. It also held that convictions for attempted first degree murder and first degree assault based on the same shot against the same victim violated double jeopardy, while convictions for the murder of one victim and attempted murder of another did not, and consecutive sentences for those offenses were proper. Justice Ireland, dissenting, would have affirmed except for dismissal of one duplicative conviction, while Justice Madsen, joined by Justice Bridge, concurred in the result but rejected automatic reversal based solely on failure to follow the closure procedure.