USA v. Paul Girard
Split Score
What is a Split Score?
This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Affirmed
The Third Circuit affirmed the convictions of Paul Girard and Kareem Harry, holding that although the courtroom was closed to in-person spectators for the first trial day and the defendants’ mothers were later kept out for several days, these Sixth Amendment public-trial violations did not warrant reversal under plain-error review. The court concluded the errors did not seriously affect the fairness or integrity of the proceedings and declined to order a retrial.
Circuit Split Identified
Legal Issue
Whether requiring all spectators to watch a criminal trial exclusively via an audiovisual overflow room constitutes a 'total closure' (triggering the Waller overriding-interest test) or only a 'partial closure' (triggering a lesser, substantial-reason test) under the Sixth Amendment public-trial right.
Circuit Positions
Remote-feed-only access is a total closure requiring an overriding interest under Waller.
Remote-feed-only access is merely a partial closure requiring only a substantial reason.
Conflict Summary
The Fifth Circuit has classified remote-feed-only access as a partial closure, thereby applying a more lenient substantial-reason standard, while the Third Circuit in this opinion rejects that view, characterizing such a restriction as a total closure that demands an overriding interest and the full Waller analysis.