Gibbons v. Savage, 555 F.3d 112 (2d Cir. 2009). Closure of voir dire proceedings for one afternoon was too trivial to warrant vacating a criminal conviction.
ABC v. Stewart, 360 F.3d 90 (2d Cir. 2004). Held district court did not set forth sufficient factual basis for closure of voir dire examinations. Vacated lower court’s order that barred the press from attending voir dire proceedings in judge’s chambers.