State v. Anderson

¶1 Calvert Anderson Jr. appeals his convictions for third degree assault and obstructing a law enforcement officer. During voir dire, Anderson successfully challenged four prospective jurors for cause at a sidebar conference. We hold that the trial court violated Anderson’s constitutional right to a public trial by allowing counsel to make juror challenges for cause at a sidebar conference without first conducting a Bone-Club1 analysis. Therefore, we reverse Anderson’s convictions and remand for a new trial.

FACTS

¶2 The State charged Anderson with third degree assault and obstructing a law…