D. Obtaining review of initial court decisions


The procedure for reviewing a trial court’s determination on closure – and for obtaining expedited or emergency review – will vary by jurisdiction. But courts have emphasized the need to resolve conflicts over access quickly, noting that “access should be immediate and contemporaneous” because “[e]ach passing day may constitute a separate and cognizable infringement of the First Amendment.”Grove Fresh Distributors, Inc. v. Everfresh Juice Co., 24 F.3d 893, 897 (7th Cir.1994). As the Supreme Court noted in another context, “the loss of First Amendment freedoms, for even minimal periods of time, unquestionably constitutes irreparable injury.” Elrod v. Burns, 427 U.S. 347, 373 (1976)

6th Cir.