State v. Bond, 2020 Ohio 398

Defendant Khairi A. Bond was indicted on two counts of murder with a firearm specification; tried by jury March 18–25, 2019 in Richland County Common Pleas.
During a March 20 recess an altercation occurred in the courthouse lobby; the trial judge thereafter limited courtroom access to immediate family for the remainder of the trial.
Bond was convicted of murder under R.C. 2903.02(B) and the firearm specification; sentenced to 15 years-to-life plus 3 years consecutive.
On appeal Bond raised four assignments: (1) denial of the right to a public trial, (2) verdict contrary to the manifest weight of the evidence, (3) improper admission of a rap song/prosecutorial misconduct, and (4) ineffective assistance of counsel.
The Fifth District applied Waller and State v. Drummond principles, found the partial closure unsupported by adequate findings, overbroad, and imposed without considering reasonable alternatives.
The court held the public-trial violation was structural error, reversed and remanded for a new trial; the remaining assignments were rendered moot.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Bond)	Held
Did limiting courtroom access violate the Sixth Amendment public-trial right?	Closure was justified by a lobby altercation and necessary to protect juror safety and courtroom order.	Closure was unsupported: no substantial reasons/findings, overbroad, no alternatives considered; violated Waller/Drummond.	Reversed — closure failed Waller/Drummond (no adequate findings, not narrowly tailored, no alternatives); structural error requires new trial.
Was the jury verdict against the manifest weight of the evidence?	Evidence supported conviction.	Verdict was against manifest weight.	Moot following reversal.
Was admission of a "gangsta" rap song and related prosecutorial conduct improper?	Admission was relevant (e.g., identity/intent/context).	Song was irrelevant/other-acts evidence and highly prejudicial; prosecutor engaged in misconduct.	Moot following reversal.
Was counsel ineffective, depriving Bond of due process?	Counsel provided adequate representation.	Counsel’s performance was deficient and prejudicial.	Moot following reversal.

Waller v. Georgia, 467 U.S. 39 (establishes public‑trial closure test and four Waller factors)
State v. Drummond, 111 Ohio St.3d 14 (Ohio Supreme Court: partial closures require a "substantial reason" and application of Waller principles)
State v. Bethel, 110 Ohio St.3d 416 (public‑trial rights are structural and cannot be waived by silence)
Press–Enterprise Co. v. Superior Court, 464 U.S. 501 (public‑access presumption and standards for restricting access)
State ex rel. The Repository v. Unger, 28 Ohio St.3d 418 (trial‑court control over proceedings; closures must be narrow and sparingly applied)
Arizona v. Fulminante, 499 U.S. 279 (distinguishing structural error from trial error)