State v. Miller

¶1 Anthony Miller appeals his convictions of conspiracy to commit murder and murder in the first degree. During a recess before beginning voir dire, the trial court dismissed a prospective juror who inadvertently had been in the courtroom while the parties and the trial court discussed pretrial issues. Miller argues that this dismissal violated his public trial right and his right to be present at critical trial stages. We hold that (1) the trial court’s pre-voir dire dismissal of the prospective juror during a recess did not implicate Miller’s public trial right and (2) even if dismissal of…