State v. Williams, 2010 Mo. App. LEXIS 1473

Williams was convicted after a jury trial of second-degree murder, three counts of first-degree assault, and four counts of armed criminal action in Missouri.
During voir dire, outbursts at the defendant led the trial court to discharge multiple panels and declare a mistrial for subsequent panels.
The court then excluded the public from jury selection to prevent contamination of the venire, limiting spectators and certain individuals from the fifth floor during voir dire.
A jury was ultimately selected and Williams was convicted; no additional public-access restrictions remained for the trial itself.
Williams argues the courtroom closure during voir dire violated his public-trial rights and raises related First Amendment standing and waiver questions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the voir dire closure violated the public-trial right	Williams	State	Waived; closure was affirmatively requested by Williams's counsel
Whether Williams waived the Sixth Amendment public-trial right	Williams	State	Waived by defense-requested closure
Whether Williams has standing to assert the public's First Amendment right to a public trial	Williams	State	No standing; Williams cannot assert the public's First Amendment rights in this context

Presley v. Georgia, 130 S. Ct. 721 (2010) (public-trial rights vs. overriding interests)
Waller v. Georgia, 467 U.S. 39 (1984) (open-trial right may yield to fair-trial interests; tailored closures require findings)
Levine v. United States, 362 U.S. 610 (1960) (public-trial right may be waived)
Gonzalez-Lopez, 548 U.S. 140 (2006) (structural rights have limits and may be waived or constrained)
State v. Brightman, 122 P.3d 150 (Wash. 2005) (public-trial/open-court considerations; factors weighing required)
Momah, 217 P.3d 312 (Wash. 2009) (voir dire closure and weighing factors; non-final authority pending)
Strode, 217 P.3d 310 (Wash. 2009) (voir dire closure; potential structural error depending on weighing factors)