People of Michigan v. Joseph Lashawn Vaughn

Summary

The Michigan Supreme Court held that a criminal defendant's Sixth Amendment right to a public trial, including public voir dire, is governed by the People v Carines forfeiture rule: silence at the time of closure forfeits rather than waives the right, and the Court of Appeals erred in treating nonassertion as necessarily foreclosing relief. Applying the four-part Carines test, the Court found the unexplained closure was plain structural error that affected substantial rights, but concluded it did not seriously affect the fairness, integrity, or public reputation of judicial proceedings given the vigorous voir dire, both parties' satisfaction with the jury, and the venire's continuing public presence, so no new trial was warranted. The Court further held that counsel's failure to object was not objectively unreasonable and that a structural error does not automatically satisfy Strickland prejudice, defeating the ineffective-assistance route to relief. The Court vacated the Court of Appeals' opinion to the extent inconsistent, affirmed its judgment on alternative grounds, and affirmed the convictions.