United States Supreme Court Reviews Criminal Conviction by Massachusetts State Court When Courtroom Was Closed During Voir Dire

Under the United States Constitution, the defendant in a criminal case has certain rights that, if violated, can potentially result in the reversal of a conviction. Among these rights are the Sixth Amendment rights to “a speedy and public trial” and “the assistance of counsel.”

A recent decision by the nation’s highest court explored whether the alleged violation of those rights in a particular Massachusetts criminal case was a basis to order a new trial.

Facts of the Case

In a recently decided case, the petitioner was a criminal defendant who was convicted of the crime of murder in a Massachusetts state trial court. During two days of the jury selection process, the courtroom was closed to the public because the courtroom was filled with potential jurors, such that the defendant’s mother and her minister were not allowed to be present inside the courtroom during voir dire. The attorney who represented the defendant at trial did not object to the trial court judge’s decision to close the courtroom. The defendant did not raise the issue in the direct appeal of his conviction but, instead, only in the context of an ineffective assistance of counsel claim some five years after his conviction.

Opinion of the United States Supreme Court

The Court affirmed the defendant’s conviction in the Massachusetts Supreme Judicial Court. While a 2010 opinion of the Court made it clear that a defendant’s right to a public trial does extend to the jury selection process, “not every public-trial violation will in fact lead to a fundamentally unfair trial.” Furthermore, even though a violation of the defendant’s right to a public trial can be classified as a structural error, counsel’s failure to object to it at trial is not always tantamount to the lack of effective assistance of counsel.

Instead, a defendant who seeks relief from a conviction on the basis of a violation of the right to a public trial during the jury selection process must either show “a reasonable probability of a different outcome in his or her case” or show “that the particular public-trial violation was so serious as to render his or her trial fundamentally unfair.” Since the defendant did not show either of these, he was not entitled to a new trial. In so holding, the court noted that generally, when a structural error was preserved and raised on direct review, a new trial would be granted as a matter of right. In the context of an ineffective assistance of counsel claim, however, the importance of the finality of the judgment requires a showing of prejudice in order for a new trial to be granted.

To Speak to an Experienced Cape Cod Criminal Defense Attorney

If you have been charged with a crime, the experienced criminal defense lawyers at the Law Offices of John C. Manoog, III, can help. Call us at 888-262-6664 to schedule a consultation at either our Plymouth or Hyannis office. Together, we can formulate a strong defense in your criminal proceedings, making sure that the Commonwealth is held to its burden of proving guilt beyond a reasonable doubt and that your constitutional rights are protected at each stage of the case.

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