Prior to the trial, the State filed a motion asking that the courtroom be closed to the public during Wilson's testimony due to Wilson's fear for his life. Wilson feared that after he testified, people in the courtroom would be able to identify him, thus making him an easier target for revenge. Prior to Wilson's testimony, the judge excluded several people from the courtroom. The Sixth Amendment is made applicable to the states through the Due Process Clause of the Fourteenth Amendment.
Public proceedings help to ensure that a defendant is treated fairly.
However, the right to a public trial is not an unlimited right. Waller, supra, at 45. Situations where other interests override the presumption of openness of the courts will be rare and a careful balancing of the interests at issue must occur. The United States Supreme Court has set forth a four-part analysis for courts to use in determining whether to close proceedings to the public. In order to obtain a reversal for a violation of the right to a public trial, a defendant does not need to show specific prejudice.