Robinson v. State, 410 Md. 91

Summary

The Maryland Court of Appeals held that Cecil Laroy Robinson failed to preserve his claim that the trial court violated his Sixth Amendment right to a public trial by excluding family members and other spectators from the courtroom. The court declined to review the merits of the courtroom-closure issue because Robinson did not object at trial and the record was insufficiently developed, and it affirmed the convictions.

Holdings

1. A defendant must make a timely objection at trial to preserve a claimed violation of the Sixth Amendment right to a public trial for appellate review.
2. The constitutional and structural-error character of an alleged denial of the right to a public trial does not excuse the failure to make a timely objection.
3. The Court would not exercise its discretion under Maryland Rule 8-131(a) or review the issue for plain error.

Questions Presented

1. Whether Robinson's challenge to the exclusion of his family and other spectators from the courtroom was preserved for appellate review when defense counsel did not object to the closure order.
2. Whether the constitutional nature and alleged structural-error character of a public-trial violation excused the failure to make a contemporaneous objection.
3. Whether the Court should exercise its discretion under Maryland Rule 8-131(a) or employ plain-error review to consider the unpreserved courtroom-closure claim.

Disposition

affirmed