Whether, as the court below and two other states hold, trial courts may close a courtroom pursuant to a closure statute without undertaking the Waller analysis; or, as nine states and the federal courts of appeals hold, the Sixth Amendment and Waller require an assessment of the specific facts of the case and proposed closure, notwithstanding the existence of a statute governing closure.

Whether trial courts may close a courtroom pursuant to a closure statute without undertaking the Waller analysis