A MANUAL OF JURY TRIAL PROCEDURES - 2004
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Chapter Two: Jury Selection

2.4     Closed Proceedings Generally

"Though criminal trials are presumptively open to the public, a court may order closure of a criminal proceeding if those excluded are afforded a reasonable opportunity to state their objections and the court articulates specific factual findings supporting closure. Such findings must establish the following: '(1) closure serves a compelling interest; (2) there is a substantial probability that, in the absence of closure, this compelling interest would be harmed; and (3) there are no alternatives to closure that would adequately protect the compelling interest.' Oregonian Publ'g Co. v. United States Dist. Court, 920 F.2d 1462, 1466 (9th Cir. 1990)." Unabom Trial Media Coalition v. United States Dist. Court, 183 F.3d 949, 951 (9th Cir. 1999) (citations omitted).