People v. Vaughn, 491 Mich. 642

Defendant Vaughn was tried in Wayne County for felon-in-possession, felony-firearm, and two counts of assault with intent to murder after a court-ordered courtroom closure during voir dire.
The circuit court closed the courtroom for voir dire without giving a reason and neither Vaughn nor his counsel objected.
Court of Appeals held that the public-trial right is forfeitable and that failure to object forecloses relief and found no ineffective-assistance claim.
Michigan Supreme Court held that the Carines forfeiture rule applies to Vaughn’s forfeited public-trial claim and that Vaughn is not entitled to relief, nor to relief for ineffective assistance.
Court reaffirmed that the right to a public trial is not expanded under the Michigan Constitution beyond the federal Sixth Amendment right, and that preservation/forfeiture standards govern unasserted claims.
The court vacated the Court of Appeals’ opinion to the extent inconsistent, affirmed the judgment on alternative grounds, and affirmed Vaughn’s convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the public-trial right can be forfeited for failure to object	Vaughn argues forfeiture should not apply to public voir dire rights.	Vaughn asserts the right can be forfeited only by personal waiver in some cases.	Carines forfeiture applies; failure to object does not automatically entitle relief
Whether Carines plain-error analysis governs unpreserved public-trial claims	Carines standard should govern unpreserved public-trial claims as plain-error.	The public-trial right is structural and may warrant automatic reversal.	Carines plain-error prongs apply; need substantial-right impact for relief
Whether the closure violated Vaughn’s Sixth Amendment right to a public trial and entitles a new trial	Closure during voir dire violated public-trial rights and deserving of new trial.	Closure did not seriously affect fairness/integrity of proceedings; no new trial.	Not entitled to new trial; closure did not seriously affect proceedings
Whether Vaughn is entitled to relief on the ineffective-assistance claim for failure to object	Counsel’s failure to object was deficient performance affecting outcome.	No prejudice; voir dire outcome remained fair and neutral.	No relief for ineffective assistance

People v Carines, 460 Mich 750 (1999) (adopts Olano forfeiture test for constitutional error)
Olano, 507 U.S. 725 (1993) (forfeiture standard for constitutional rights)
Waller v. Georgia, 467 U.S. 39 (1984) (public-trial rights and prejudice standard; open trial benefits)
Presley v. Georgia, 130 S. Ct. 721 (2010) (public-trial right during voir dire; First/Second Amendment context)
Neder v. United States, 527 U.S. 1 (1999) (structural errors and automatic reversal framework)
Duncan v. Michigan, 462 U.S. 137; 610 N.W.2d 551 (2000) (structural errors are intrinsically harmful; automatic reversal guidance)
Hill v. United States, 527 U.S. 110 (2000) (personal and informed waiver concept for fundamental rights)
Johnson v. United States, 520 U.S. 461 (1997) (reserved judgment on structural error and forfeiture interplay)