State v. Shearer, 334 P.3d 1078

Washington Constitution article I, section 22 guarantees a right to a public trial to preserve fairness and accountability.
2012 decisions (Wise, Paumier, Sublett) held the public-trial right applies to jury selection and required a Bone-Club analysis before private juror questioning; without it closures are error.
In Grisby and Shearer, trial courts conducted in-chambers voir dire without Bone-Club analysis; no on-record findings supported closure.
The State urged overruling two 2012 holdings: waiver by absence of objection and treating public-trial violations as structural errors.
The Court applies the 2012 framework and finds both Grisby and Shearer violated public-trial rights by closing part of voir dire without Bone-Club analysis; de minimis rationale rejected.
Court concludes public-trial rights can be raised on appeal even without trial objection; de minimis closures are not permitted; remands for new trials where appropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Waiver of public-trial rights on appeal without objection	Shearer/Grisby can raise rights despite no objection	State seeks overrule waiver rule	Yes; rights may be raised on appeal without contemporaneous objection
Whether closures were de minimis	Closures violated Bone-Club factors	Closures were de minimis	No; closures were not de minimis; structural error

State v. Wise, 176 Wn.2d 1 (2012) (public trial right applies to voir dire; Bone-Club factors required for closure)
State v. Paumier, 176 Wn.2d 29 (2012) ( Bone-Club analysis required; public-trial rights not waived by lack of objection)
State v. Sublett, 176 Wn.2d 58 (2012) (plurality on public-trial closures; openness of trial as standard)
State v. Bone-Club, 128 Wn.2d 254 (1995) (Bone-Club framework for closing proceedings)
State v. Easterling, 157 Wn.2d 167 (2006) (public-trial openness; exceptions analyzed)