closure hearing (New York) · Go Syfert
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closure hearing in New York

10 New York opinions name it 1 courts 1991–2019 0 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (3)

CaseFollowedCited
People v. Saundersgreen
nyappdiv · 1995 · cited in 1 New York opinions naming this issue, 2019–2019
1 sentence

2019We decline to exercise our power to review that contention as a matter of discretion in the interest of justice ( see CPL 470.15 [6] [a]), and we further conclude that [*2]defendant was not denied meaningful representation when trial counsel failed to object to the closure inasmuch as "the prosecution established on the record adequate reasons for the closure even if defense counsel had challenged it" ( People v Torres , 300 AD2d 221, 222 [1st Dept 2002], lv denied 99 NY2d 659 [2003]; see also People v Simmons , 220 AD2d 629, 630 [2d Dept 1995], lv denied 87 NY2d 907 [1995]).

11
People v. Torresgreen
nyappdiv · 2002 · cited in 1 New York opinions naming this issue, 2019–2019
1 sentence

2019We decline to exercise our power to review that contention as a matter of discretion in the interest of justice ( see CPL 470.15 [6] [a]), and we further conclude that [*2]defendant was not denied meaningful representation when trial counsel failed to object to the closure inasmuch as "the prosecution established on the record adequate reasons for the closure even if defense counsel had challenged it" ( People v Torres , 300 AD2d 221, 222 [1st Dept 2002], lv denied 99 NY2d 659 [2003]; see also People v Simmons , 220 AD2d 629, 630 [2d Dept 1995], lv denied 87 NY2d 907 [1995]).

11
Somerville v. Goordgreen
nyappdiv · 2004 · cited in 1 New York opinions naming this issue, 2005–2005
1 sentence

2005Although there is some confusion in the record as to whether petitioner actually received the log book entries requested after the Hearing Officer ordered them produced, petitioner did not object prior to the closure of the hearing and thereby waived this claim (see Matter of Somerville v Goord, 12 AD3d 823, 824 [2004]).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (25)

CaseCitedYears
People v. Skinner green
nyappdiv · 1994
2 sentences

1997This testimony sufficiently supports the order of closure (see, People v Mitchell, 209 AD2d 444 ; People v Thompson, 202 AD2d 454 ; People v Campbell, 204 AD2d 474 ; People v Hosien, 204 AD2d 658 ; People v Skinner, 204 AD2d 664 ; People v Jamison, 203 AD2d 385 ; People v Leybovich, 201 AD2d 670 ).

1995These facts meet the requirements for closure under People v Martinez ( 82 NY2d 436, 442 ) (see, People v Mitchell, 209 AD2d 444 ; People v Skinner, 204 AD2d 664 ).

21995–1997
People v. Mitchell green
nyappdiv · 1994
2 sentences

1997This testimony sufficiently supports the order of closure (see, People v Mitchell, 209 AD2d 444 ; People v Thompson, 202 AD2d 454 ; People v Campbell, 204 AD2d 474 ; People v Hosien, 204 AD2d 658 ; People v Skinner, 204 AD2d 664 ; People v Jamison, 203 AD2d 385 ; People v Leybovich, 201 AD2d 670 ).

1995These facts meet the requirements for closure under People v Martinez ( 82 NY2d 436, 442 ) (see, People v Mitchell, 209 AD2d 444 ; People v Skinner, 204 AD2d 664 ).

21995–1997
People v. Green neutral
nyappdiv · 2000
1 sentence

2001Moreover, the information revealed to the court at the closure hearing was similar to information already relayed to it at a proceeding, lawfully conducted ex parte (CPL 240.90 [3]), on the People’s application for a discovery protective order (see, People v Green, 277 AD2d 11 , supra).

12001–2001
People v. Martin green
ny · 1980
1 sentence

1999Since defendant failed to make a timely objection, which would have permitted the court to rectify the situation instantly by making more detailed findings, defendant failed to preserve his present claim (see, CPL 470.05 [2]; People v Martin, 50 NY2d 1029, 1031 ), and we decline to review it in the interest of justice.

11999–1999
People v. Leybovich green
nyappdiv · 1994
1 sentence

1997This testimony sufficiently supports the order of closure (see, People v Mitchell, 209 AD2d 444 ; People v Thompson, 202 AD2d 454 ; People v Campbell, 204 AD2d 474 ; People v Hosien, 204 AD2d 658 ; People v Skinner, 204 AD2d 664 ; People v Jamison, 203 AD2d 385 ; People v Leybovich, 201 AD2d 670 ).

11997–1997
People v. Thompson green
nyappdiv · 1994
1 sentence

1997This testimony sufficiently supports the order of closure (see, People v Mitchell, 209 AD2d 444 ; People v Thompson, 202 AD2d 454 ; People v Campbell, 204 AD2d 474 ; People v Hosien, 204 AD2d 658 ; People v Skinner, 204 AD2d 664 ; People v Jamison, 203 AD2d 385 ; People v Leybovich, 201 AD2d 670 ).

11997–1997
People v. Brakas green
nyappdiv · 1994
1 sentence

1997This testimony sufficiently supports the order of closure (see, People v Mitchell, 209 AD2d 444 ; People v Thompson, 202 AD2d 454 ; People v Campbell, 204 AD2d 474 ; People v Hosien, 204 AD2d 658 ; People v Skinner, 204 AD2d 664 ; People v Jamison, 203 AD2d 385 ; People v Leybovich, 201 AD2d 670 ).

11997–1997
People v. Hosien neutral
nyappdiv · 1994
1 sentence

1997This testimony sufficiently supports the order of closure (see, People v Mitchell, 209 AD2d 444 ; People v Thompson, 202 AD2d 454 ; People v Campbell, 204 AD2d 474 ; People v Hosien, 204 AD2d 658 ; People v Skinner, 204 AD2d 664 ; People v Jamison, 203 AD2d 385 ; People v Leybovich, 201 AD2d 670 ).

11997–1997
People v. Jamison neutral
nyappdiv · 1994
1 sentence

1997This testimony sufficiently supports the order of closure (see, People v Mitchell, 209 AD2d 444 ; People v Thompson, 202 AD2d 454 ; People v Campbell, 204 AD2d 474 ; People v Hosien, 204 AD2d 658 ; People v Skinner, 204 AD2d 664 ; People v Jamison, 203 AD2d 385 ; People v Leybovich, 201 AD2d 670 ).

11997–1997
People v. Graham green
nyappdiv · 1994
1 sentence

1995Under these circumstances, the court did not improvidently exercise its discretion by extending the closure of the courtroom to the defendant’s family (see, People v Graham, 200 AD2d 686 ).

11995–1995
People v. Martinez green
ny · 1993
1 sentence

1995These facts meet the requirements for closure under People v Martinez ( 82 NY2d 436, 442 ) (see, People v Mitchell, 209 AD2d 444 ; People v Skinner, 204 AD2d 664 ).

11995–1995
People v. Policano green
nyappdiv · 1988
1 sentence

1993Under these circumstances, the Supreme Court properly granted the application and was not required, sua sponte, to order the officer in question to appear for a full hearing (see, People v Pollock, 50 NY2d 547 ; People v Jones, 47 NY2d 409 , cert denied 444 US 946 ; People v Policano, 139 AD2d 773 ).

11993–1993
Robinson v. United States green
scotus · 1979
1 sentence

1993Under these circumstances, the Supreme Court properly granted the application and was not required, sua sponte, to order the officer in question to appear for a full hearing (see, People v Pollock, 50 NY2d 547 ; People v Jones, 47 NY2d 409 , cert denied 444 US 946 ; People v Policano, 139 AD2d 773 ).

11993–1993
People v. Pollock green
ny · 1980
1 sentence

1993Under these circumstances, the Supreme Court properly granted the application and was not required, sua sponte, to order the officer in question to appear for a full hearing (see, People v Pollock, 50 NY2d 547 ; People v Jones, 47 NY2d 409 , cert denied 444 US 946 ; People v Policano, 139 AD2d 773 ).

11993–1993
People v. Jones green
ny · 1979
1 sentence

1993Under these circumstances, the Supreme Court properly granted the application and was not required, sua sponte, to order the officer in question to appear for a full hearing (see, People v Pollock, 50 NY2d 547 ; People v Jones, 47 NY2d 409 , cert denied 444 US 946 ; People v Policano, 139 AD2d 773 ).

11993–1993
People v. Richards neutral
ny · 1991
1 sentence

1991When an officer is actively engaged in the community as an undercover agent, the court may exercise its discretionary power to seal the courtroom during the undercover officer’s testimony (see, People v Hinton, 31 NY2d 71 , cert denied 410 US 911 ; People v Richards, 157 AD2d 753 , affd 77 NY2d 969 ; People v Flores, 152 AD2d 704 ).

11991–1991
People v. Velasco green
ny · 1991
1 sentence

1991It is settled that a defendant’s presence may be dispensed with during purely ministerial proceedings, wholly unrelated to the substantive legal or factual issues of the trial (see, People v Velasco, 77 NY2d 469 ; People v Harris, 76 NY2d 810, 812 ; People v Rodriguez, 76 NY2d 918 ; People v Ferguson, 67 NY2d 383 ), or in situations where his presence would be "useless, or the benefit but a shadow” (Snyder v Massachusetts, supra, at 106-107 ).

11991–1991
Snyder v. Massachusetts green
scotus · 1934
2 sentences

1991Moreover, the closure hearing did not constitute a material stage of the trial during which the defendant’s presence was required in order to safeguard his constitutional and statutory rights (see, People v Mullen, 44 NY2d 1 , 4-5, citing Snyder v Massachusetts, 291 US 97, 108 ).

1991It is settled that a defendant’s presence may be dispensed with during purely ministerial proceedings, wholly unrelated to the substantive legal or factual issues of the trial (see, People v Velasco, 77 NY2d 469 ; People v Harris, 76 NY2d 810, 812 ; People v Rodriguez, 76 NY2d 918 ; People v Ferguson, 67 NY2d 383 ), or in situations where his presence would be "useless, or the benefit but a shadow” (Snyder v Massachusetts, supra, at 106-107 ).

11991–1991
People v. Duffy neutral
nyappdiv · 1989
1 sentence

1991When an officer is actively engaged in the community as an undercover agent, the court may exercise its discretionary power to seal the courtroom during the undercover officer’s testimony (see, People v Hinton, 31 NY2d 71 , cert denied 410 US 911 ; People v Richards, 157 AD2d 753 , affd 77 NY2d 969 ; People v Flores, 152 AD2d 704 ).

11991–1991
People v. Rivera neutral
nyappdiv · 1990
1 sentence

1991When an officer is actively engaged in the community as an undercover agent, the court may exercise its discretionary power to seal the courtroom during the undercover officer’s testimony (see, People v Hinton, 31 NY2d 71 , cert denied 410 US 911 ; People v Richards, 157 AD2d 753 , affd 77 NY2d 969 ; People v Flores, 152 AD2d 704 ).

11991–1991
People v. Harris green
ny · 1990
1 sentence

1991It is settled that a defendant’s presence may be dispensed with during purely ministerial proceedings, wholly unrelated to the substantive legal or factual issues of the trial (see, People v Velasco, 77 NY2d 469 ; People v Harris, 76 NY2d 810, 812 ; People v Rodriguez, 76 NY2d 918 ; People v Ferguson, 67 NY2d 383 ), or in situations where his presence would be "useless, or the benefit but a shadow” (Snyder v Massachusetts, supra, at 106-107 ).

11991–1991
Hinton v. New York green
scotus · 1973
1 sentence

1991When an officer is actively engaged in the community as an undercover agent, the court may exercise its discretionary power to seal the courtroom during the undercover officer’s testimony (see, People v Hinton, 31 NY2d 71 , cert denied 410 US 911 ; People v Richards, 157 AD2d 753 , affd 77 NY2d 969 ; People v Flores, 152 AD2d 704 ).

11991–1991
People v. Hinton green
ny · 1972
1 sentence

1991When an officer is actively engaged in the community as an undercover agent, the court may exercise its discretionary power to seal the courtroom during the undercover officer’s testimony (see, People v Hinton, 31 NY2d 71 , cert denied 410 US 911 ; People v Richards, 157 AD2d 753 , affd 77 NY2d 969 ; People v Flores, 152 AD2d 704 ).

11991–1991
People v. Ferguson green
ny · 1986
1 sentence

1991It is settled that a defendant’s presence may be dispensed with during purely ministerial proceedings, wholly unrelated to the substantive legal or factual issues of the trial (see, People v Velasco, 77 NY2d 469 ; People v Harris, 76 NY2d 810, 812 ; People v Rodriguez, 76 NY2d 918 ; People v Ferguson, 67 NY2d 383 ), or in situations where his presence would be "useless, or the benefit but a shadow” (Snyder v Massachusetts, supra, at 106-107 ).

11991–1991
People ex rel. Richards v. Bartlett green
ny · 1990
1 sentence

1991It is settled that a defendant’s presence may be dispensed with during purely ministerial proceedings, wholly unrelated to the substantive legal or factual issues of the trial (see, People v Velasco, 77 NY2d 469 ; People v Harris, 76 NY2d 810, 812 ; People v Rodriguez, 76 NY2d 918 ; People v Ferguson, 67 NY2d 383 ), or in situations where his presence would be "useless, or the benefit but a shadow” (Snyder v Massachusetts, supra, at 106-107 ).

11991–1991

Where else courts name it

WA 22 (1995–2025) NY 10 (1991–2019) OH 8 (1994–2013) AZ 5 (2001–2025) SC 5 (1994–2006) SD 4 (1990–2015) NV 3 (1987–2025) FL 3 (1980–1987) MA 3 (2014–2018) UT 2 (1984–1987) CA 2 (1999–2009) OR 2 (2016–2019) MN 2 (2000–2007) VA 2 (1981–2012) IL 2 (2009–2009) NJ 2 (1983–1990)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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