No. 20-633October Term 2020Decided Mar 22, 2021Updated Mar 22, 2021
Smith v. Titus
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.
Case status
Decided · March 22, 2021
Read the opinion (PDF)- 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
Timing
Decided March 22, 2021
The Court released its decision on March 22, 2021 without hearing oral argument.
Documents
Activity
Docket activity2
Opinion added: Opinion
Mar 22, 2021 | Court records
Brief added: Petition
Nov 5, 2020 | Court records
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Grounding
- Grounding
- Primary-source trail available.
- Note
- Plain-English explainer. Official filings and opinions remain authoritative.
- Checked
- Jul 25, 2026
- Method
- Methodology