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The Supreme Court has not directly addressed this subject, but lower courts have extended the presumption of access to post-trial civil proceedings. InNewman v. Graddick, 696 F.2d 796, 801 (11th Cir. 1983), for example, the court recognized a constitutional right of access to post-trial proceedings in a civil case dealing with prisoners’ rights.
No Oregon court has specifically addressed access to post-trial proceedings. However, the Oregon Constitution provides a presumption of access unless the proceeding is not an adjudication, or where the proceeding was traditionally closed prior to the adoption of the Oregon Constitution. See Oregonian Publishing Co. v. O’Leary, 303 Or, 297, 303, 736 P.2d 173 (1987).
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