as implicating the constitutional guarantee”); Carson v. Fischer, 421 F.3d 83, 92 (2d Cir. 2005) (“[e]ven an unjustified closure may, in some circumstances, be so trivial as not to implicate the right to a public trial”); People v. Webb, 267 Ill. App. 3d 954, 959, 642 N.E.2d 871, 205 Ill. Dec. 6 (1994) (“the defendant’s right to a public trial was not violated” by a de minimis closure); People v. Woodward, 4 Cal. 4th 376, 384-86, 841 P.2d 954, 14 Cal. Rptr. 2d 434 (1992) (applying the “de minimis rationale” and concluding that the right to a public trial was not violated); State v. Lindsey, 632 N.W.2d 652, 660-61 (Minn. 2001) (applying a “triviality standard” and concluding that no violation of the right to a public trial occurred); State v. Torres, 844 A.2d 155, 162 (R.I. 2004) (<HOLDING>). ¶32 Critically, courts that have found a
holding the sixth amendment applicable to the states through the fourteenth amendment recognizing that the sixth amendment is not violated every time the public is excluded from a courtroom an unjustified closure may on its facts be so trivial as not to violate the sixth amendment guarantee holding that rule 606b does not violate the sixth amendment holding that the court lacks jurisdiction over sixth amendment claims because the sixth amendment is not moneymandating holding that some closures are too trivial to implicate the sixth amendment right to a public trial