State v. Jones, 303 P.3d 1084

Jones was convicted of attempted first degree murder; he challenges an off-record, court-recess drawing of four alternate jurors as a violation of the public trial right, urging per se prejudice and remand for a new trial.
The court drew alternate jurors during a recess without open-court Bone-Club analysis, triggering recent Washington public-trial jurisprudence recognizing structural error.
The opinion also addresses Jones’s other claims (unreliable photo identification, defense-evidence restrictions, and pro se grounds), finding none reversible.
Factual backdrop includes the February 13, 2010 shooting of Trooper Johnson, subsequent photomontages, Johnson’s identification of Jones, and searches that connected Jones to the crime.
Pretrial history includes venue changes due to publicity and rulings on admissibility of certain evidence and identification-related challenges.
Trial proceeded for five weeks with voir dire, then the off-record alternate juror drawing occurred after closing arguments; no objection was raised at the time.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did off-record alternate juror drawing close public access?	Jones argues closure violated public trial rights	Jones contends the drawing was off-record and lacked Bone-Club analysis	Yes; constitutes a per se public-trial violation requiring new trial
Did drawing alternates outside Jones’s presence violate right to be present or to appear and defend?	Irby/Irby-like concerns about presence during juror selection	Drawing was not a critical phase and did not affect defense	Not violated; if error, harmless beyond a reasonable doubt
Do the remaining claims (photo ID, defense evidence, pro se challenges) reverse the conviction?	Additional grounds affect trial fairness	Arguments do not amount to reversible error	No reversible error established

State v. Wise, 176 Wn.2d 1 (Wash. 2012) (public trial right; per se prejudice when closure unaddressed)
State v. Sublett, 176 Wn.2d 58 (Wash. 2012) (experience and logic test for public-trial closure)
State v. Paumier, 176 Wn.2d 29 (Wash. 2012) (Bone-Club analysis prerequisites for closure)
State v. Bone-Club, 128 Wn.2d 254 (Wash. 1995) (Bone-Club five-factor closure test)
Gagnon, 470 U.S. 522 (U.S. Supreme Court, 1985) (due process present during trial-related proceedings)
Snyder v. Massachusetts, 343 U.S. 23 (U.S. Supreme Court, 1952) (presence substantially relates to the opportunity to defend)
Rushen v. Spain, 464 U.S. 114 (U.S. Supreme Court, 1983) (harmless error framework for presence right)
Irby, 170 Wn.2d 874 (Wash. 2011) (right to be present during jury selection; due process considerations)
Caliguri, 99 Wn.2d 501 (Wash. 1983) (appearance and defense rights; substantial rights trigger)
Press-Enter. Co. v. Superior Court, 464 U.S. 501 (U.S. Supreme Court, 1984) (experience and logic in public-access analysis)
State v. Gentry, 125 Wn.2d 570 (Wash. 1995) (participation in juror selection; impact of alternate juror deliberations)