Steadman v. State
2012 Tex. Crim. App. LEXIS 474
| Tex. Crim. App. | 2012Background
- Appellant Jeffrey Steadman was convicted in a single jury trial of three counts of aggravated sexual assault of a child and two counts of indecency with a child.
- The trial court excluded four of Steadman’s family members from the voir dire in the jury-selection phase, asserting security and decorum concerns.
- Steadman objected to the exclusion as a Sixth Amendment public-trial violation; the trial court recorded extensive findings on remand.
- The Court of Appeals initially upheld the closure under Waller v. Georgia, and Presley v. Georgia was issued during the pendency of the appeal.
- The Texas Court of Criminal Appeals held the closure violated the Sixth Amendment and remanded for a new trial.
- Remedy: new trial on remand due to public-trial violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether excluding Steadman’s family from voir dire violated the Sixth Amendment. | Steadman | State | Yes; closure not justified. |
| Whether the trial court’s remand findings were sufficiently concrete under Waller/Presley. | Steadman | State | Insufficient; not concrete enough. |
| Whether reasonable alternatives to closure were considered. | Steadman | State | Not adequately explored. |
| Whether Presley applies retroactively to require reversal and new trial. | Steadman | State | Presley applies; requires new trial. |
| What remedy follows a public-trial violation during voir dire. | Steadman | State | New trial (remand) required. |
Key Cases Cited
- Waller v. Georgia, 467 U.S. 39 (1984) (public-trial right requires specific findings and narrow closure)
- Presley v. Georgia, 130 S. Ct. 721 (2010) (Sixth Amendment extends to voir dire; require concrete findings and alternatives)
- Duncan v. Louisiana, 391 U.S. 145 (1968) (public-trial rights incorporated via due process)