The First Amendment right of access extends to civil trials. Am. Civil Liberties Union v. Holder, 673 F.3d 245, 252 (4th Cir. 2011) (citations omitted); Rushford v. New Yorker Magazine, Inc., 846 F.2d 249, 253 n.4 (4th Cir. 1988).
“All trials upon the merits of every court of justice shall be conducted in open court and so far as convenient in a regular courtroom.” Idaho R. Civ. Pro. 77(b); see also Idaho R. Civ. Proc. 43(a) (“In all trials the testimony of witnesses shall be taken orally in open court, unless otherwise provided by statute or by these rules, the Idaho Rules of Evidence, or other rules adopted by the Supreme Court of Idaho”); Saint Alphonsus v. St. Luke’s Health Sys., Ltd., Case Nos. 1:12-CV-00560-BLW and 1:13-CV-00116-BLW (D. Idaho) (discussing issue of access to civil court proceedings where confidential documents are offered as exhibits and used by testifying witnesses).
Pennsylvania courts have recognized both a constitutional and common law right of access to civil proceedings generally. See PA Child Care LLC v. Flood, 887 A.2d 309, 312 (Pa. Super. 2005) (“Pennsylvania has a mandate for open and public judicial proceedings both in the criminal and civil settings.”).