State v. Strode

¶1 We have plainly articulated the guidelines that every trial court must follow before it closes a courtroom to the public. State v. Bone-Club, 128 Wn.2d 254, 258-59, 906 P.2d 325 (1995). In the Bone-Club case, we held that a courtroom may be closed to the public only when the criteria for closure identified in that case are satisfied. Here, the trial court violated Tony Strode’s right to a public trial by conducting a portion of jury selection in the trial judge’s chambers in unexceptional circumstances without first performing the required Bone-Club analysis. This is a structural error…