Id. at 572, 100 S.Ct. 2814. Although “[wjhether the public has a right to attend trials of civil cases [was] a question not raised by this case,” Chief Justice Burger noted that “historically both civil and criminal trials have been presumptively open.” Id. at 580 n. 17, 100 S.Ct. 2814; see also id. at 599, 100 S.Ct. 2814 (Stewart, J., concurring) (“[T]he First and Fourteenth Amendments clearly give the press and the public a right of access to trials themselves, civil as well as criminal.”). The Court of Appeals for the Second Circuit subsequently confirmed that the right recognized by Richmond Newspapers extends to civil trials. See Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir.1984). See also Publicker Indus., Inc. v. Cohen, 733 F.2d 1059, 1071 (3d Cir.1984) (<HOLDING>); In re Cont’l Ill. Sec. Lit., 732 F.2d 1302,
holding that a defendant has right to be represented by counsel in all criminal trials for serious offenses holding that absolute prosecutorial immunity extends to civil forfeiture proceedings holding that juveniles are not entitled to jury trials holding the sixth amendment right to effective assistance extends to a criminal defendants first appeal as of right holding that right recognized by richmond newspapers extends to civil trials