State v. Magnano, 326 P.3d 845

Matthew Magnano was convicted of second-degree robbery; a 911 audio recording made by the victim was admitted at trial without objection and played once for the jury.
After closing arguments, counsel and the court agreed which exhibits would go to the jury and discussed procedures if the jury requested to replay the 911 tape.
During deliberations the jury asked to rehear the 911 recording; defense counsel and Magnano (by phone) stated they had no objection to replaying the tape.
The court authorized the bailiff to play the tape in the courtroom during deliberations but closed the courtroom door and instructed the bailiff to prevent public entry to protect deliberation secrecy; no formal Bone-Club closure analysis was conducted.
Magnano appealed, arguing the closed-courtroom replay violated his and the public’s right to a public trial under the Sixth Amendment and article I, §§10 and 22 of the Washington Constitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether replaying an admitted 911 recording for the jury in a closed courtroom during deliberations implicates the public-trial right	Magnano: replay in closed courtroom was a closure of the proceeding and violated defendant’s and public’s right to open trials	State: rehearing admitted evidence during deliberations is governed by CrR 6.15(f)(1) and does not historically or logically require public access; closure did not implicate public-trial right	Court held no public-trial right attached; replaying properly admitted recorded evidence in closed courtroom during deliberations did not implicate public-trial right and conviction affirmed

State v. Sublett, 176 Wn.2d 58 (2012) (adopts the experience-and-logic test to determine when public-trial protections attach)
State v. Wise, 176 Wn.2d 1 (2012) (defendant’s right to public trial is constitutional and evaluated de novo)
State v. Bone-Club, 128 Wn.2d 254 (1995) (sets five-factor test required for permissible courtroom closures)
Press-Enter. Co. v. Superior Court, 478 U.S. 1 (1986) (experience-and-logic framework for public access analysis)
State v. Castellanos, 132 Wn.2d 94 (1997) (permits unlimited jury access to contemporaneous audio exhibits; distinguishes replayed testimony)
State v. Frazier, 99 Wn.2d 180 (1983) (discusses court control over jury replay of taped evidence to avoid undue emphasis)
State v. Elmore, 155 Wn.2d 758 (2005) (jury secrecy and impartiality principles require privacy of deliberations)