State v. Pinno

¶ 1. These cases are before the court on certification by the court of appeals, *116pursuant to Wis. Stat. § (Rule) 809.61 (2011-12).1 The court of appeals certified both State v. Pinno and State v. Seaton because these unrelated cases present the question whether the closure2 of a public criminal trial without objection from the defendant is subject to a waiver analysis or a forfeiture analysis on review.3

¶ 2. Fond du Lac County Circuit Judge Richard J. Nuss (Judge Nuss) presided over jury trials in Pinno and Seaton, including the voir dire proceedings. In both voir dire proceedings, the judge…