1. In Presley v. Georgia, 558 U.S. 209 (2010), this Court held the right to a public trial in criminal cases extends to the entire trial, and any closure must be justified by an overriding governmental interest. Given that holding, have the federal courts of appeals undermined these constitutional principles by adopting a test that requires a lesser governmental interest to justify a closure that is deemed "partial."

2. The qualified right to counsel of choice is both the core of the Sixth Amendment right to counsel, and independent of the Sixth Amendment's guarantee of a fair trial. Accordingly, can the denial of counsel of choice occurring during post-trial proceedings be evaluated for harmless error?

Whether federal courts have undermined the constitutional principles of the right to a public trial by adopting a test that requires a lesser governmental interest to justify a 'partial' closure