State v. Hood, 320 P.3d 522

Hood convicted of trafficking cocaine after undercover purchase; habitual offender enhancement; total term 18 years.
State moved to close courtroom during Officer Bloomfield’s testimony to conceal undercover identity.
District court relied on asserted safety interests but offered no admissible evidence or findings; sealed information later unsealed.
Closure covered the entire courtroom to all members of the public during Bloomfield’s testimony.
Turrietta adopts the Waller four-pronged test for closures and requires findings, alternatives, and narrowly tailored closure.
Appellate court reversed and remanded for new trial, and suggested rulemaking to govern motions for closure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether courtroom closure during Bloomfield’s testimony violated the public-trial right.	State argues overriding interest likely prejudiced public testimony.	Hood contends closure was unconstitutional under Turrietta/Waller.	Unconstitutional; prongs two-four not satisfied; remand.
Whether the district court failed to make necessary findings and consider alternatives.	State claims no further findings were needed.	Court should have evaluated alternatives; burden on court.	Fourth Waller prong not met; insufficient findings and alternatives.
Whether the State adequately considered reasonable alternatives to closure.	State claimed alternatives were not viable.	Defendant proposed alternatives, which were not adequately considered.	Third Waller prong not satisfied; alternatives not properly evaluated.

Turrietta v. State, 308 P.3d 964 (NMSC 2013) (adopts Waller four-prong test for closures; requires tailored closure and findings)
Waller v. Georgia, 467 U.S. 39 (1984) (establishes overriding-interest standard for courtroom closures)
Sherlock, United States v., 962 F.2d 1349 (9th Cir. 1989) (examples of reasonable alternatives to closure)