No. 20-633October Term 2020Decided Mar 22, 2021
Smith v. Titus
For now, the key dispute is whether federal courts must treat the Sixth Amendment public-trial right as broad or narrow when reviewing state convictions under AEDPA.
Case status
- Current stage
- Decided
- Latest event
- Decision released Mar 22, 2021
- What it's about
Byron David Smith, a state prisoner seeking federal habeas relief, argues that his Sixth Amendment right to a public trial was violated when the courtroom was closed during part of his criminal proceedings. The case asks how broadly the public-trial right applies when a federal court reviews a state conviction under AEDPA.
Question presented
The question presented by this petition is whether the Sixth Amendment’s public trial guarantee, within the review apparatus imposed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) applies (1) to all phases of a defendant’s criminal trial; or (2) only to pretrial suppression hearings and juror voir dire.
- Case path
United States Court of Appeals for the Eighth Circuit / Decision released Mar 22, 2021
- Area
Decided Supreme Court case
Briefing
What it's about
Byron David Smith, a state prisoner asking a federal court to review his conviction, says his Sixth Amendment right to a public trial was violated when the courtroom was closed during part of his criminal case. The petition asks whether, under AEDPA, that public-trial protection applies across the whole trial or only to proceedings like suppression hearings and jury selection.
Vote
No oral argument has been scheduled yet. Smith argues that the public-trial right should apply more broadly when federal courts review state convictions under AEDPA.
Impact
The answer could affect how hard it is for state prisoners to challenge courtroom closures in federal court. For example, a defendant whose family was excluded from part of a trial could face different odds depending on how broadly the right is read.
What's next
The next milestone is any move by the Court on whether to take the case or set further scheduling. No oral argument date or decision window is available yet.
What is the core dispute in Smith v. Titus?
The case asks how far the Sixth Amendment's public-trial right extends in federal review of a state conviction. The specific question is whether it covers all trial phases or only certain ones.
Why could this case matter beyond Byron David Smith?
It could shape when prisoners can win federal challenges to courtroom closures. That matters to defendants, families, victims, and the public interest in open courtrooms.
What should court watchers look for next in this case?
Watch for the Supreme Court to decide whether to hear the petition or make another scheduling move. There is no argument date yet.
Decision
What the Court decided
For now, the key dispute is whether federal courts must treat the Sixth Amendment public-trial right as broad or narrow when reviewing state convictions under AEDPA.
Impact
The answer could affect how hard it is for state prisoners to challenge courtroom closures in federal court. For example, a defendant whose family was excluded from part of a trial could face different odds depending on how broadly the right is read.
Not official Court text.
Opinion documents
Timing
Decided March 22, 2021
The Court released its decision on March 22, 2021 without hearing oral argument.
Documents
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Jul 2, 2026
- Method
- Methodology