GALLARDO ET AL.

v.

QUINLAN ET AL.

Citator

Cited By

• Woods v. Kuhlmann, 977 F.2d 74 (2d Cir. 1992)
  …pelling interest, was necessary and had been articulated, defendant’s right to a public trial had not been violated), petition for cert, filed, No. 92-5433 (U.S. July 27, 1992); Nieto v. Sullivan, 879 F. 2d 743, 753 (10th Cir.) (same), cert. denied, 493 U.S. 957, 110 S.Ct. 373, 107 L.Ed.2d 359 (1989); Douglas v. Wainwright, 739 F. 2d 531, 533 (11th Cir.1984) (per curiam) (same), cert. denied, 469 U.S. 1208, 105 S.Ct. 1170, 84 L.Ed.2d 321 (1985). These courts reasoned that a less stringent standard was just…
• United States v. Galloway, 963 F.2d 1388 (10th Cir. 1992)
  …are instructive. In Nieto v. Sullivan, we affirmed the court’s decision to exclude the defendant’s relatives during the testimony of a witness who told the judge he feared retribution. 879 F. 2d 743, 749-51 and nn. 11, 13 (10th Cir.), cert. denied, 493 U.S. 957, 110 S.Ct. 373, 107 L.Ed.2d 359 (1989). The Ninth Circuit upheld a partial closure when the trial judge observed a rape victim’s “apprehension in testifying before [the defendant’s] family members”, who were “making faces and giggling during her t…