See State v. Drake, 701 SW 2d 604, 608-09 (Tenn. 1985):
Typically a motion for a closure order will be made by a defendant, will be unopposed by the State, and if any evidence or advocacy is offered in opposition, it will likely be on behalf of media entities.
"[A]lthough the public has a qualified [constitutional] right of access to civil court proceedings and records, the trial court may limit this right when there is a compelling countervailing public interest and closure of the court proceedings or sealing of documents is required to protect such countervailing public interest. In performing this analysis, the trial court must consider alternatives to closure. Unless such an overriding interest exists, the civil court proceedings and records will be open to the public.
As noted above in Part I.C; inDes Moines Register & Tribune Co. v. Iowa Dist. Court for Story County, 426 N.W.2d 142, 147-48 (Iowa 1988), the court adopted the procedural requirements of Press Enterprise II to require specific factual findings on the grounds for closure and satisfaction of the Wifvat standard. See alsoinfra Part II.A.