Byron Smith v. Jeff Titus, 958 F.3d 687

On Thanksgiving 2012 Byron Smith shot and killed two intruders in his home; he claimed self‑defense.
Smith sought to introduce testimony that one victim had participated in prior burglaries of his house; trial court issued public pretrial orders limiting such evidence.
At the first day of trial, before the jury was sworn, the trial judge briefly cleared the public and media from the courtroom to explain and articulate the parameters of the earlier written evidentiary ruling; the proceeding was transcribed and lasted only minutes.
The courtroom was then reopened, the jury was sworn, and the trial proceeded; Smith was convicted and sentenced to life terms.
The Minnesota Supreme Court held the short nonpublic proceeding was administrative (like a bench conference) and did not implicate the Sixth Amendment public‑trial right; Smith sought federal habeas relief claiming the state decision misstated federal law.
The federal district court denied relief under AEDPA; the Eighth Circuit affirmed, holding the state decision was not contrary to or an unreasonable application of clearly established Supreme Court precedent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the brief nonpublic proceeding before the jury was sworn violated the Sixth Amendment right to a public trial	Smith: closure denied public‑trial right; Waller standards should have been applied	State/Trial court: proceeding was administrative/bench‑conference in nature, brief, transcribed, and did not implicate the Sixth Amendment	The court held the Minnesota Supreme Court reasonably treated the proceeding as administrative and not a public‑trial violation; no Sixth Amendment breach shown
Whether the Minnesota decision was contrary to or an unreasonable application of Supreme Court precedent under AEDPA	Smith: Minnesota decision conflicts with Waller and Presley and is objectively unreasonable	State: Waller and Presley addressed suppression hearings and voir dire; AEDPA requires deference and fairminded jurists could disagree	The court held the state court’s ruling was not contrary to or an unreasonable application of clearly established federal law; AEDPA bars habeas relief

State v. Smith, 876 N.W.2d 310 (Minn. 2016) (state court decision concluding the brief nonpublic proceeding was administrative and did not violate the Sixth Amendment)
Waller v. Georgia, 467 U.S. 39 (1984) (established four‑part test to justify closure of criminal proceedings)
Presley v. Georgia, 558 U.S. 209 (2010) (held closure of jury selection violated public‑trial right and Waller standards apply)
Williams v. Taylor, 529 U.S. 362 (2000) (defines "contrary to" and "unreasonable application" for AEDPA review)
Yarborough v. Alvarado, 541 U.S. 652 (2004) (explains objective unreasonableness standard under AEDPA)
Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA limits habeas relief to extreme malfunctions; requires deference)
Press‑Enterprise Co. v. Superior Court of Cal., 464 U.S. 501 (1984) (discusses historical right of public and press to attend certain criminal proceedings)
United States v. Norris, 780 F.2d 1207 (5th Cir. 1986) (upheld private bench conferences for legal arguments as not violating public‑trial right)