State v. Williams

Summary

The South Carolina Supreme Court reviewed the closure of a pretrial suppression hearing in a capital murder case. The court held that the trial court's concerns about publicity, domestic violence, and racial issues did not satisfy the constitutional requirements for closure because closing the hearing would not prevent the anticipated prejudice, and it reversed the closure order while rejecting the media appellants' procedural due process claim.

Holdings

1. The test for reviewing the propriety of closing a courtroom under the South Carolina Constitution is identical to the First Amendment analysis: closure requires specific findings establishing a substantial probability of prejudice, a substantial probability that closure will prevent the prejudice, and the inadequacy of reasonable alternatives.
2. The closure was improper because the trial court's concerns about additional publicity, domestic violence, racial issues, and disclosure of confession details did not establish that closure would prevent prejudice; reasonable alternatives, including limiting the hearing to legal arguments and using voir dire, were available.
3. The trial court did not violate the appellants' procedural due process rights because the appellants were alerted to the proposed closure, requested a hearing, and received a meaningful opportunity to present arguments through counsel.

Questions Presented

1. Whether the trial court closed the pretrial suppression hearing without sufficient constitutional justification.
2. Whether the trial court violated the appellants' procedural due process rights by closing the courtroom without adequate notice and a meaningful opportunity to be heard.

Disposition

reversed