Vernon Bowden v. John Keane, Superintendent, Woodbourne Correctional Facility, and Eliot Spitzer, Attorney General of New York

JOSÉ A. CABRANES, Circuit Judge:

We review a judgment of the United States District Court for the Southern District of New York (John E. Sprizzo, Judge) denying appellant Vernon Bowden’s petition for a writ of habeas corpus on the ground that closure of the courtroom during Bowden’s trial did not violate his rights under the Sixth Amendment to the United States Constitution. Under the framework established in Waller v. Georgia, 467 U.S. 39, 104 S.Ct. 2210, 81 L.Ed.2d 31 (1984), a criminal trial may be closed to the public only if “[1] the party seeking to close the hearing ... advance[s] an…