rejecting argument that locking doors during jury instructions violated Sixth Amendment because ”[t]he trial remained open to the public and press already in the courtroom and the trial court never ordered the removal of any member of the public, the press, or the defendant's family”
How later courts described this case
- rejecting argument that locking doors during jury instructions violated Sixth Amendment because ”[t]he trial remained open to the public and press already in the courtroom and the trial court never ordered the removal of any member of the public, the press, or the defendant's family”
- stating that if one prong of plain-error standard is not met, appellate courts need not analyze remaining prongs
- finding error trivial when judge locked courtroom during reading of jury instructions in order to keep the jury attentive
- stating that a plain-error claim may fail on any one prong
Written by the judges who cited it.
Distinguished
Distinguished by State v. Silvernail, 2013 Minn. LEXIS 306 (2013)
In fact, Brown is distinguishable only because the closure in this case occurred at a different stage of the criminal trial: the State’s closing argument rather than the reading of the jury instructions.
The opinion
ANDERSON, PAUL H., Justice
(dissenting).
I join in the dissent of Justice Meyer.