by a State to prevent subsequent review by [federal courts] of a federal constitutional claim.” Ford v. Georgia, 498 U.S. 411, 423-24, 111 S.Ct. 850, 112 L.Ed.2d 935 (1991) (quoting James v. Kentucky, 466 U.S. 341, 348-49, 104 S.Ct. 1830, 80 L.Ed.2d 346 (1984)). Because I believe the waiver rule in the courtroom closure context was neither firmly established nor regularly followed by Minnesota courts when Crawford’s public trial claim was deemed waived, I respectfully dissent. When the Minnesota Court of Appeals heard Crawford’s appeal there was just one published appellate case, post Waller v. Georgia, 467 U.S. 39, 104 S.Ct. 2210, 81 L.Ed.2d 31 (1984), which employed the waiver rule in the context of a courtroom closure. See State v. Bashire, 606 N.W.2d 449, 452 (Minn.Ct.App.2000) (<HOLDING>). In State v. Anderson, No. C2-95-1087, 1995 WL
holding plaintiffs waived their right to appellate review of the admission of an experts testimony by failing to object to it at trial holding the defendant waived any claim of error by both failing to object at trial and affirmatively agreeing to a limited closure holding that a defendant waived a sentencing issue by failing to object in district court holding the defendant waived his courtroom closure challenge because he both failed to object to the limited closure and agreed to the closure through his attorney holding that statutory grounds for recusal can be waived both by failing to object and by failing to assert error on appeal