Peyronel, Bobby Joe, PD-1274-14

Appellant Bobby Joe Peyronel was convicted of aggravated sexual assault of a child; jury assessed 50 years’ imprisonment.
During punishment, a female family member approached a juror and asked, “How does it feel to convict an innocent man?” prompting concerns about juror intimidation.
The prosecutor asked the court to exclude female family members from the courtroom; the judge invoked the Rule and ordered spectators (including those female relatives) to wait outside during further proceedings.
Appellant’s trial counsel responded that the exclusion was “too broad” as to wife and daughter but did not expressly object on public-trial grounds or request any specific relief or ruling.
The First Court of Appeals reversed the punishment judgment, holding the courtroom exclusion violated the public-trial right. The State seeks discretionary review arguing the issue was not preserved for appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the public-trial complaint was preserved for appeal	State: Peyronel failed to timely and specifically object; therefore he waived the public-trial claim	Peyronel: Trial response amounted to an objection preserving public-trial claim; appellate reversal of punishment was correct	Court of Appeals held issue preserved and reversed punishment; State urges this Court to reverse that holding as unpreserved because counsel never requested relief or stated public-trial grounds at trial

Blue v. State, 41 S.W.3d 129 (Tex. Crim. App. 2000) (preservation rule requires timely objection stating specific grounds)
Waller v. Georgia, 467 U.S. 39 (1984) (public-trial right overview and its purposes)
Levine v. United States, 362 U.S. 610 (1960) (general objections insufficient to preserve public-trial claim)
Coble v. State, 330 S.W.3d 253 (Tex. Crim. App. 2010) (failure to object at trial forfeits public-trial complaint on appeal)
Martinez v. State, 22 S.W.3d 504 (Tex. Crim. App. 2000) (objection requirement gives trial court chance to correct error)