Document Type
Case Summary
Publication Date
6-27-2024
Case Synopsis
The Nevada Supreme Court determined that the District Court violated Christopher Deangelo Palmer’s Sixth Amendment right to a public trial by excluding his entire family from the courtroom during the complaining witness’s testimony without satisfying the four-factor test established in Waller v. Georgia. The Court found that the reasons provided for the partial closure, such as maintaining courtroom control, the misbehavior of Palmer’s brother, and Palmer’s recorded jail calls, did not constitute substantial reasons for the closure of the court. The District Court failed to consider reasonable alternatives to the closure and did not make sufficient findings to support its decision. This violation is a structural error, and as such, the Nevada Supreme Court reversed Palmer’s judgment of conviction and remanded for a new trial.
Recommended Citation
Malters, Matthew, "Palmer (Christopher) v. State of Nevada, 130 Nev. Adv. Op. 41 (Jun. 27, 2024)" (2024). Nevada Supreme Court Summaries. 1698.
https://scholars.law.unlv.edu/nvscs/1698