United States v. Gupta

HALL, Circuit Judge:

This appeal presents the narrow question of whether the district court’s intentional closure of the courtroom during voir dire violated Defendant-Appellant Raghubir K. Gupta’s right to a public trial. In Waller v. Georgia, 467 U.S. 39, 48, 104 S.Ct. 2210, 81 L.Ed.2d 31 (1984), the Supreme Court held that, consistent with the Sixth Amendment, a trial court may exclude the public from the courtroom only upon satisfaction of a four-factor test, and in Presley v. Georgia, 558 U.S. 209, 130 S.Ct. 721, 724, 175 L.Ed.2d 675 (2010), the Supreme Court reiterated that this test…