could have allowed one to two more spectators to sit with Mrs. Bucci, Mrs. Keefe, and Mrs. Jordan. It is, however, of no constitutional moment that the court did not do so. 9 . Indeed, Mrs. Keefe — whose testimony showed her to be a devoted mother who carefully followed every moment of the trial, talked to her son every day during his incarceration, and even led the effort to collect affidavits for Bucci’s habeas petition — was likely the most important member of the public to be present from Bucci’s perspective. Hr’g Tr. vol. 2 at 30, 33. 10 . Other jurisdictions that have considered this issue have also held that prohibiting public ingress and egress during a jury charge does not constitute "closure” under the Sixth Amendment. E.g., Herring v. Meachum, 11 F.3d 374, 380 (2d Cir.1993) (<HOLDING>); Bell v. Evatt, 72 F.3d 421, 433 (4th
holding that trial court did not err in refusing to give charge because plaintiff failed to demonstrate that his requested charge was tailored to the evidence holding that counsel was deficient when he failed to object to error in jury charge referring to aggravated assault when the charge was assault on a public servant holding trial courts error in overruling objection to prosecutors misstatement of law of intoxication that differed from definition in charge was harmless when there was evidence supporting the jurys verdict and it was presumed the jury followed the instructions in the charge holding that trial was never closed when court locked doors during jury charge because all members of the public who wanted to observe the charge were permitted to do so if there was enough space and they arrived in time holding that because trial court actually gave part of a jury charge that appellant claimed was improperly omitted and because remainder of courts charge adequately defined one of the legal terms at issue the courts jury charge taken as a whole was not misleading and did not constitute reversible error