Farrington v. People, 2011 V.I. Supreme LEXIS 25

Farrington was convicted of one count of Third-Degree Robbery and two counts of Grand Larceny in the Virgin Islands.
He contends his Sixth Amendment right to a public trial was violated when family and a friend were allegedly barred from voir dire.
He argues prosecutorial comments during closing arguments were improper and denied him a fair trial.
Trial court denied his motions for a new trial; no explicit finding of courtroom closure was made at first, leading to a remand for an evidentiary hearing.
Jury verdict occurred January 22, 2010; final judgment entered June 24, 2010; the appellate court affirms on the non-public-trial issue and remands on the public-trial issue.
Court remands for evidentiary hearing to determine whether the public was denied access during voir dire; otherwise, no error found in closing arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Public trial right during voir dire	Farrington claims public access was denied	State/Trial Court did not close the courtroom; no evidence of closure	Remanded for evidentiary hearing to determine closure facts
Prosecutor’s closing arguments	Prosecutor’s comments were improper and biased	Comments were permissible and did not impair fairness	Not error; affirmed with remand on public-trial issue separately

Presley v. Georgia, 130 S. Ct. 721 (2010) (public-trial right extends to voir dire; existence of closure must meet stringent standards)
Press-Enterprise Co. v. Superior Court of Cal., 464 U.S. 501 (1984) (closure permissible only with specific conditions and findings)
Waller v. Georgia, 467 U.S. 39 (1984) (public access protects integrity of judicial process)
Gannett Co. v. DePasquale, 443 U.S. 368 (1979) (public trial rights serve defendant and public confidence in justice)
Donelly v. DeChristoforo, 416 U.S. 637 (1974) (standard for analyzing prosecutorial misconduct)