polling). In contrast, the defendant’s and the public’s right to open and public trials also encompasses circumstances in which the public’s mere presence passively contributes to the fairness of the proceedings, such as deterring deviations from established procedures, reminding the officers of the court of the importance of their functions, and subjecting judges to the check of public scrutiny. See, e.g., Brightman, 155 Wn.2d at 514; Leyerle, 158 Wn. App. at 479. ¶12 Thus, even in proceedings involving purely legal matters, the public’s presence may ensure the fairness of such proceedings, although the same cannot be said for ministerial or administrative matters that do not impact the defendant’s rights. But see In re Det. of Ticeson, 159 Wn. App. 374, 383-86, 246 P.3d 550 (2011) (<HOLDING>). ¶13 Sadler is broadly cited for the
holding that washington law historically supports inchambers conferences on purely legal issues holding that a section 225 action should not be used for trying purely collateral issues holding the court need not rule on remaining issues when the disposition of prior issues is dispositive holding that state law controlled damage issues holding that state law controls whether issues decided in a prior state court action are entitled to preclusive effect and setting forth the elements of collateral estoppel under washington law