56 N.Y.2d 870 (1982)
Before excluding the press from a pretrial hearing (specifically, a Sandoval hearing), a trial court must conduct a preliminary inquiry to determine whether closure is warranted, and must articulate its reasons for closure on the record.
Summary
During a criminal trial, the defendant requested a Sandoval hearing to determine the admissibility of his prior criminal acts for impeachment purposes if he testified. The trial court, at the defendant’s request, summarily excluded a reporter from the hearing. The Court of Appeals held that the trial court erred by failing to conduct a preliminary inquiry before closing the hearing to the press. The Court emphasized the public interest in Sandoval hearings due to the significance of the rulings and their impact on the defendant’s decision to testify. The Court mandated that all proceedings on the motion, whether in open court or in camera, should be recorded for appellate review, and the reasons for closure should be given in open court.
Facts
During the midtrial of a criminal case, the defendant requested a hearing under People v. Sandoval to determine which, if any, of his prior criminal acts would be admissible to impeach his credibility if he chose to testify. A reporter from Capital Newspapers sought permission to attend the hearing. The trial court, acting at the defendant’s instance, summarily denied the reporter’s request and closed the hearing.
Procedural History
The petitioner, Capital Newspapers, challenged the trial court’s decision to exclude their reporter. The Appellate Division’s judgment was appealed to the Court of Appeals.
Issue(s)
Whether a trial court must conduct a preliminary inquiry before excluding the press from a pretrial Sandoval hearing held during a criminal trial.
Holding
Yes, because despite the potential prejudice to the defendant, there is a genuine public interest in Sandoval hearings, thus requiring a preliminary inquiry before closure to the press.
Court’s Reasoning
The Court of Appeals reversed the Appellate Division’s judgment, emphasizing the necessity of a preliminary inquiry before excluding the press from the Sandoval hearing. The court drew upon the procedural prescriptions set forth in Matter of Westchester Rockland Newspapers v. Leggett, which established guidelines for balancing the public’s right to access court proceedings with a defendant’s right to a fair trial. The court acknowledged that the Sandoval hearing was not part of the trial itself, nor was it directly related to the issue of guilt or innocence. However, it recognized the significant public interest in such hearings, given the importance of the rulings made and their potential impact on the defendant’s decision to testify. The court stated that the procedures laid down in Leggett and Hearst Corp. v. Clyne should have been followed, requiring that “all proceedings on the [defendant’s] motion, whether in open court or in camera, should [have been] recorded for appellate review” and “the reasons for closure [should have been] given in open court” (quoting Matter of Westchester Rockland Newspapers v. Leggett, 48 N.Y.2d 430, 442). Because no such preliminary inquiry was conducted, the Court did not reach the question of whether the reporter should have been permitted to attend the hearing. The Court’s decision underscores the importance of transparency in judicial proceedings and the need for a careful balancing of competing interests when considering closure motions. This case is significant because it extends the preliminary inquiry requirement to pretrial hearings that, while not directly determinative of guilt or innocence, are nonetheless important to the administration of justice and of public interest. The practical implication is that trial courts must follow specific procedures to justify closing such hearings to the press and public.