38. The holdings in Scott and similar cases are in line with the trial judge’s inherent power to “impose reasonable limitations on access to a trial” to ensure the fair and efficient administration of justice. Press-Enterprise, 464 U.S. at 510 n. 10, 104 S.Ct. 819 (citing Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 581 n. 18, 100 S.Ct. 2814, 65 L.Ed.2d 973 (1980)); Scott, 564 F.3d at 38-39 (praising trial court for preserving defendant’s right to a public trial “while also facilitating the orderly and efficient functioning of the courtroom”). See also Meachum, 11 F.3d at 380 (“Reasonable time, place, and manner limitations on access to the courtroom are permitted to ensure the fair and efficient administration of justice.”); Snyder v. Coiner, 510 F.2d 224, 230 (4th Cir.1975) (<HOLDING>). In Bucci’s case, as in the jury charge cases,
holding that judge had power to limit ingress and egress of persons during counsels final arguments because it was a reasonable limitation to prevent disturbance holding that appellant landowner who complained of a sewer pipe being laid offshore his property had the incorporeal right to free ingress and egress to abutting navigable waters recognizing that a principal may limit the authority of its agent and such limitation will be binding on a third party who is aware of the limitation holding that regulatory restrictions on abutting landowners right of ingress and egress are not compensable when landowner has adequate alternative means to access property holding that it is inappropriate to make a claim to the jury during closing arguments when no evidence hals been presented during trial to support it