State v. Turrietta, 308 P.3d 964

Turrietta was convicted of second-degree murder with firearm enhancement and related offenses after a trial.
The district court partially closed the courtroom during the testimony of two confidential informants due to gang threats and presence.
The Court of Appeals affirmed, applying a “substantial reason” standard for partial closures.
The Supreme Court granted certiorari to reject the pre-Presley authority and adopt the Waller standard for closures.
The Court held there was no Brady violation and remanded for a new trial consistent with its opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether partial courtroom closure violated the public-trial right	Turrietta argues closure violated Sixth Amendment public-trial right	Turrietta asserts closure was unconstitutional under Waller	Closure unconstitutional; adopt Waller standard
Whether the closure’s rationale satisfied overriding interests	State claims threats justified closure	Defendant contends threats were not adequately tied to the case	Not satisfied; closure not justified under Waller
Whether there was a Brady violation regarding informant deals	Turrietta contends suppressed deal information biased witnesses	State argues no Brady materials were suppressed	No Brady violation

Waller v. Georgia, 467 U.S. 39 (1984) (overriding-interest four-part test for closures; requires findings, etc.)
Presley v. Georgia, 558 U.S. 209 (2010) (requires rigorous analysis of closure under Waller; Presley standard cited for procedures)
Press-Enterprise Co. v. Superior Court of California, Riverside County, 464 U.S. 501 (1984) (four-pronged overriding-interest framework for closures)
Drummond v. Houk, 854 N.E.2d 1038 (Ohio 2006) (discussed as authority on closure findings (state appellate discussions))
Ayala v. Speckard, 131 F.3d 62 (2d Cir. 1997) (discussed for alternatives to closure)
Longus v. State, 7 A.3d 64 (Md. 2010) (partial closures and tailoring of exclusions)
United States v. Sherlock, 962 F.2d 1349 (9th Cir. 1989) (discussed in context of alternatives to closure)