Vernon Bowden v. John Keane, Superintendent, Woodbourne Correctional Facility, and Eliot Spitzer, Attorney General of New York

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that the testimony put forth during the closure “was by no means essential to the government’s case”
• stating that justifying fear in “rough terms” is sufficient to satisfy the first Waller requirement
• noting that “every other circuit to address the issue” has “held Gradsky, 434 F.2d 8 80, 882 (5th Cir. 1970
• noting that the Waller test must be satisfied for \non-trivial courtroom closures\ (emphasis added)
• providing that whether a closure is broad or narrow depends on factors including its duration, whether transcripts of the closed proceedings are made available, and whether the closure applied to selected persons or the entire public
• while specific findings required before complete closure, “competent evidence from the record” can support partial closure

Source: CourtListener parenthetical corpus (CC0).