Uniko Carson v. Brian Fischer, Superintendent, Sing Sing Correctional Facility, Eliot L. Spitzer, New York State Attorney General

B.D. PARKER, JR., Circuit Judge.

This appeal requires us to consider whether, when a defendant’s ex-mother-in-law is excluded from a limited portion of a criminal trial that is attended by other members of the defendant’s family, law enforcement personnel, counsel, and a jury, the Sixth Amendment’s public trial guarantee requires granting habeas corpus relief absent particularized findings justifying the exclusion. While the Sixth Amendment generally requires specialized findings before family members and friends can be excluded, under the unique circumstances presented here, we conclude that…