Campbell v. State, 240 Md. App. 428

Clyde Campbell was tried for the murder of Dorothy Grubb; a jury convicted him of second-degree murder and he was sentenced to 30 years.
Family members (including his son and sister) were present in the courtroom on day one of voir dire but were excluded by order of the trial court on the second day during part of voir dire and for the entire jury selection and swearing-in; exclusion lasted about 3–3.5 hours.
The State asked for exclusion citing concerns that family members had been perceived as seated in the jury box and potential fraternization with prospective jurors; defense objected and argued space was available and family provided emotional support.
The parties completed peremptory strikes and impaneled the jury while family was excluded; the jury was sworn and trial proceeded without family present for those stages.
On appeal Campbell argued the exclusion violated his Sixth Amendment right to a public trial (and sought suppression rulings, including a Miranda-waiver challenge); the Court of Special Appeals reversed the conviction and remanded for a new trial on Sixth Amendment grounds, and rejected the Miranda-waiver challenge.

Issue	Plaintiff's Argument (Campbell)	Defendant's Argument (State)	Held
Whether excluding Campbell’s family during part of voir dire and the entire jury selection and swearing-in violated the Sixth Amendment right to a public trial	Exclusion of family from voir dire, jury selection, and swearing-in implicated core public-trial values and was not de minimis; Waller required findings and consideration of alternatives	Exclusion was de minimis (about 3 hours), analogous to Kelly v. State; record silent on whether the public generally was excluded, so closure was only partial	Court held the closure was not de minimis (three+ hours and exclusion during jury selection and swearing-in) and reversed: trial court failed to apply Waller (did not consider alternatives or make adequate findings), requiring a new trial
Whether Campbell’s waiver of Miranda rights was knowing and voluntary	Waiver invalid because detective allegedly suggested warnings applied only to unrelated weapons warrant and not to questioning about Grubb	Detective read Miranda warnings fully; suspect was told choice to speak was his; Spring and Miranda precedent make knowledge of specific topics irrelevant to a valid waiver	Court held the waiver was knowing and voluntary; awareness of every possible subject is not required, so statements were admissible (no suppression)

Watters v. State, 328 Md. 38 (Md. 1992) (closure of entire morning including voir dire and jury impaneling violated Sixth Amendment)
Kelly v. State, 195 Md. App. 403 (Md. Ct. Spec. App. 2010) (de minimis closure test: length, significance, scope)
Waller v. Georgia, 467 U.S. 39 (U.S. 1984) (four-factor test to justify courtroom closure)
Presley v. Georgia, 558 U.S. 209 (U.S. 2010) (trial court must consider alternatives to closure during jury selection)
In re Oliver, 333 U.S. 257 (U.S. 1948) (historical and public-trial values)
Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (peremptory strike limits and public oversight interest)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (warnings and waiver principles)
Colorado v. Spring, 479 U.S. 564 (U.S. 1987) (waiver validity does not require awareness of all possible interrogation subjects)