Capital Newspapers Division of the Hearst Corp. v. Clyne, 52 N.Y.2d 436 (1981)
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Before excluding the press from a pretrial hearing, such as a Sandoval hearing, a trial court must conduct a preliminary inquiry to determine whether closure is warranted, considering the public interest and potential prejudice to the defendant.
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Summary
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During a criminal trial, the defendant requested a Sandoval hearing to determine the admissibility of prior bad acts for impeachment purposes should he testify. The trial court, at the defendant’s request, closed the hearing to the press, including a reporter from Capital Newspapers. The New York Court of Appeals held that the trial court erred by not conducting a preliminary inquiry before closing the hearing. The Court emphasized that while the hearing wasn’t part of the trial itself, there is a genuine public interest in such hearings, necessitating a preliminary inquiry to balance the public’s right to access and the defendant’s right to a fair trial.
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Facts
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During a criminal trial, the defendant requested a hearing pursuant to 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.
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A reporter from Capital Newspapers sought permission to attend the hearing.
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The trial court, acting at the defendant’s request, summarily denied the reporter’s request and closed the hearing.
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Procedural History
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The trial court closed the Sandoval hearing to the press.
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Capital Newspapers challenged the closure.
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The Appellate Division’s judgment was reversed by the Court of Appeals, and the case was remitted to the Appellate Division for entry of a judgment declaring that the trial court erred in not conducting a preliminary inquiry.
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Issue(s)
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Whether a trial court must conduct a preliminary inquiry before excluding the press from a pretrial hearing, such as a Sandoval hearing, to determine if closure is warranted.
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Holding
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Yes, because the procedures laid down in Matter of Westchester Rockland Newspapers v Leggett and Matter of Hearst Corp. v Clyne should have been followed, requiring a preliminary inquiry to balance the public interest against the defendant’s right to a fair trial. The court stated 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”.
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Court’s Reasoning
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The Court of Appeals reasoned that while a Sandoval hearing isn’t part of the trial itself and doesn’t directly involve the defendant’s guilt or innocence, there is still a