People v. Echevarria, 21 N.Y.3d 1

Three defendants (Echevarria, Moss, Johnson) were charged in buy-and-bust drug-sale cases in northern Manhattan and East Harlem.
Courts held Hinton hearings to decide whether to close the courtroom during undercover officers’ testimony to protect safety and ongoing investigations.
Closures were narrowly tailored: the courtrooms were closed during specific officers’ testimony, with limited exceptions for family members attending trials.
At trial, testimony from the undercover officers was in closed sections, while other witnesses testified openly in court.
Echevarria challenged a jury agency-charge instruction; Moss and Johnson challenged only the courtroom closures as applied to their trials.
This Court held: closures were constitutionally permissible under Waller prong analysis, but Echevarria required a new trial due to error in the agency-defense jury instruction; Moss and Johnson upheld.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether closure satisfied Waller prong one (overriding interest).	Moss and Johnson: sufficient nexus between officer safety and closed testimony.	Moss and Johnson: geographic vagueness undermines nexus; Echevarria was similar but not identical.	Prong one satisfied; closures upheld.
Whether trial courts adequately addressed Waller prong three (reasonable alternatives).	Presley requires explicit on-record consideration of alternatives; Ramos allows implied consideration.	Absent explicit discussion of alternatives, reversal is required.	No prong three violation under Presley/Ramos as record supports implied consideration.
Whether the jury instruction on the agency defense was proper for Echevarria (and Johnson).	Agency defense properly conveyed by listing factors; Johnson adequate.	Echevarria’s charge was imbalanced and improperly limited; omitted key factors.	Echevarria: new trial ordered due to erroneous agency-charge instruction; Moss/Johnson affirmed.

Ramos v. New York, 90 N.Y.2d 490 (1997) (upholds implied consideration of alternatives to closure in buy-and-bust cases; governs prong three analysis)
Waller v. Georgia, 467 U.S. 39 (1984) (four-part test for courtroom closures; need adequate findings)
Press-Enterprise Co. v. Superior Court, Riverside County, 464 U.S. 501 (1984) (prong three requires consideration of alternatives; bulk closures scrutinized)
Press-Enterprise Co. v. Superior Court, Riverside County (II), 478 U.S. 1 (1986) (limits on breadth of closure; requires alternatives to total suppression)
Presley v. Georgia, 558 U.S. 209 (2010) (requires trial courts to consider reasonable alternatives to closure even if not raised by parties)
People v. Martinez, 82 N.Y.2d 436 (1993) (limits on nexus between safety concerns and open testimony; specificity required)
People v. Ayala, 90 N.Y.2d 490 (1997) (specificity of area of operation supports closure when coupled with threats)
People v. Roche, 45 N.Y.2d 78 (1978) (agency defense factors; substantial evidence standard for defense viability)
People v. Lam Lek Chong, 45 N.Y.2d 64 (1978) (no rigid formula; jurors rely on common sense for agency defense)
People v. Umali, 10 N.Y.3d 417 (2008) (agency-defense framework and juror understanding of factors)
People v. Jones, 96 N.Y.2d 213 (2001) (undercover safety nexus and closure analysis in buy-and-bust cases)
People v. Ortiz, 76 N.Y.2d 446 (1990) (agency defense principle and philosophy)