STATE OF MISSOURI v. JOHNNY R. DAVIS, JR.

Johnny Davis appeals his convictions for kidnapping and first-degree assault. He complains, in part, that closing the courtroom during voir dire violated his right to a public trial. We agree.

Thirty years ago in Waller v. Georgia, 467 U.S. 39, 45-48, 104 S.Ct. 2210, 81 L.Ed.2d 31 (1984), the Supreme Court affirmed that public criminal trial guarantees extended to voir dire and pretrial hearings, and described a four-part test for courts to assure that any “rare” closure would pass constitutional muster.

Four years ago, reiterating that “Waller provided standards for courts to apply before…