In the case of Eric Presley v. Georgia, 2009, the U.S. Supreme Court ruled in favor of Presley who argued that his Sixth Amendment right to a public trial was violated when the court excluded his uncle from jury selection during his trial for cocaine trafficking. The State of Georgia had argued that this exclusion was necessary to protect juror privacy and ensure an unbiased jury pool. However, the Supreme Court disagreed with this argument stating that courts are required to consider reasonable alternatives before closing proceedings and excluding members of the public from any stage of a criminal trial without sufficient justification violates defendants' rights under both the Sixth Amendment's Public Trial Clause and First Amendment’s Right-to-Access Doctrine.

In the case of Eric Presley v. Georgia, there was no dissenting opinion recorded by any justice of the Supreme Court. The court unanimously ruled in favor of Presley, holding that his Sixth Amendment right to a public trial was violated when the trial court excluded his uncle from voir dire over Presley's objection. The decision emphasized that courts are required to consider reasonable alternatives before closing proceedings and must make findings adequate to support closure even for short periods.