State v. Turrietta, 258 P.3d 474

Defendant Turrietta, member of BBK, was tried for murder in the second degree with firearm enhancement, shooting from a vehicle resulting in great bodily harm, aggravated battery with a deadly weapon, and tampering with evidence after a 2006 Albuquerque gang-related shooting.
Two confidential informants (Torrez and Morales) testified via a partially closed courtroom due to threats and gang presence in the gallery; the court allowed a partial courtroom closure to protect witnesses and the integrity of the proceedings.
Additional witnesses (Ayala and Neal) testified; the court kept the proceedings largely open for them, with some closures for Torrez and Morales based on threat evidence and gang activity.
Defense moved to compel production of gang files and disclosure of motives/benefits for informants; responses included in-camera review and protective orders, with limited disclosure.
During trial, Morales disclosed a deal with the State in exchange for testimony; other informants indicated possible incentives but no definitive deals proven at trial; the State disclosed relevant information promptly.
Jury convicted Turrietta on all counts; the district court proceedings included evidentiary and closure rulings challenged on Sixth Amendment and Brady grounds; the Court of Appeals affirmed the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did partial courtroom closure violate the Sixth Amendment?	Turrietta argues closure violated public-trial rights.	State asserts threat and safety needs justify partial closure.	Partial closure upheld; narrowly tailored to protect witnesses and court.
Was there a Brady violation due to suppressed or undisclosed evidence?	Turrietta contends the State suppressed gang files and informant deals.	State contends no suppression; any deals disclosed; evidence irrelevant or immaterial.	No Brady violation; disclosures were timely and not material to guilt.
Does the record warrant cumulative error relief?	Turrietta asserts cumulative errors affected fairness.	State maintains no trial errors occurred cumulatively.	No cumulative error; convictions affirmed.

In re Oliver, 333 U.S. 257 (1948) (public-trial right applies to states; not absolute in all contexts)
Waller v. Georgia, 467 U.S. 39 (1984) (closure standards require overriding interests and alternatives)
Presley v. Georgia, 130 S. Ct. 721 (2010) (public-trial right must be balanced; partial closures can be permissible)
State v. Slayton, 147 N.M. 340 (2009-NMSC-054) (standard for reviewing closure decisions; mixed questions of law/fact)
State v. Brown, 139 P.3d 753 (2006-NMSC-023) (public-trial considerations under state constitution alignment with federal standards)
State v. Drummond, 854 N.E.2d 1038 (2006-Ohio-5084) (dangerousness of gang violence can justify targeted closures)
Case v. Hatch, 183 P.3d 905 (2008-NMSC-024) (prosecutorial misconduct reviewed under abuse-of-discretion standard)
Ayala v. Speckard, 131 F.3d 62 (1997) (sua sponte consideration of alternatives to closure; liminal standards)