State v. Castro, 246 P.3d 228

Castro was convicted of possessing cocaine after a pretrial in limine motion process.
Defense sought to exclude witnesses, limit undisclosed witnesses, bar impeachment, and avoid hearsay/improper opinions.
On the trial's first day, the judge ruled on the motions in chambers, ruling in Castro's favor on all four.
The court later placed its rulings on the open record inviting objections from counsel; Castro did not object.
The jury subsequently convicted Castro; he appealed claiming a violation of the public trial right.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did in-chambers ruling on in limine violate public trial?	Castro argues Bone-Club requires public resolution.	Castro contends no public closure occurred or required Bone-Club analysis.	No Bone-Club analysis required; no public-trial violation.

State v. Bone-Club, 128 Wash.2d 254 (1995) (closure factors for public-trial considerations)
State v. Momah, 217 P.3d 321 (Wash. 2009) (public trial protections; openness in criminal proceedings)
State v. Strode, 217 P.3d 310 (Wash. 2009) (public trial considerations in criminal trials)
State v. Easterling, 137 P.3d 825 (Wash. 2006) (Bone-Club framework and public access)
State v. Rivera, 32 P.3d 292 (Wash. App. 2001) (public hearing not required for purely ministerial or legal issues)
State v. Sadler, 193 P.3d 1108 (Wash. App. 2008) (public trial applies to evidentiary phases; no right to public hearing on ministerial issues)
State v. Sublett, 231 P.3d 231 (Wash. App. 2010) (in-chambers conference not a public hearing when no disputed facts)