State Of Washington, V. Miguel Antonio Bejar, Jr., 491 P.3d 229

Bejar was convicted of first-degree murder with a firearm enhancement and unlawful possession of a firearm after a drive-by shooting; the prosecution argued the killing occurred in the context of a gang war.
There were documented incidents of witness violence and social-media posts threatening or identifying alleged snitches, and one State witness had been shot; the prosecutor sought enhanced courtroom security to prevent witness intimidation.
The trial court ordered secondary screening outside the courtroom (magnetometer, handheld detector, pat downs) and prohibited electronic recording devices in the courtroom; jurors initially were required to pass the secondary screening.
The court stated the order’s purposes included providing a fair trial, preserving dignity of proceedings, and ensuring witness safety; the court expressed intent to post the order on the courtroom door and to apply screening to multiple courtrooms.
After the first day the court amended its order so jurors could bypass screening with juror badges; later amendments allowed retrieval of devices during recess.
Bejar appealed, arguing the screening and posting were inherently prejudicial (violating presumption of innocence) and that the court failed to make required written findings; the Court of Appeals reviewed for abuse of discretion and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether requiring jurors to undergo secondary screening on the first day (and posting the security order) was inherently prejudicial	Screening and posting were neutral, routine security measures necessary to prevent witness intimidation and protect safety given past assaults, shootings, and social-media threats	Screening and the posted order (which mentioned "ensure witness safety") singled out defendants as dangerous, undermining presumption of innocence and prejudicing the jury	Not inherently prejudicial: court applied Holbrook/Hayes/Jaime reasoning, emphasized screening was routine, applied to multiple courtrooms, located outside the room, and jurors could bypass after day one; affirmed
Whether the trial court abused its discretion by failing to issue written, case-specific findings to justify secondary screening	Oral, case-specific findings on the record sufficed; no authority requires written findings for these measures	Court needed written findings specific to the measures to justify intrusion and guard against prejudice	No abuse of discretion: court made case-specific oral findings (gang violence, social-media threats, witness assaults, inability to monitor cellphones) and the appellate court declined to impose a written-findings requirement; affirmed

Holbrook v. Flynn, 475 U.S. 560 (1986) (presence of courtroom security/guards is generally not inherently prejudicial)
Hayes v. Ayers, 632 F.3d 500 (9th Cir. 2011) (entry-screening procedures like metal detectors and pat-downs are not inherently prejudicial)
State v. Jaime, 168 Wn.2d 857 (2010) (trial in a jailhouse courtroom can be inherently prejudicial because the setting is not neutral)
State v. Dye, 178 Wn.2d 541 (2013) (trial-court trial-management and security rulings reviewed for abuse of discretion)
State v. Gorman-Lykken, 9 Wn. App. 2d 687 (2019) (case-specific findings required when security officer is stationed next to witness stand)
State v. Jasper, 174 Wn.2d 96 (2012) (on appellate presumptions when the record is partial)