“Historically both civil and criminal trial has been presumptively open.” See Richmond Newspapers Inc., v. Virginia, 448 U.S. 555, 580 (1980).

In Richmond the court stated, “People in an open society do not demand infallibility from their institutions, but it is difficult for them to accept what they are prohibited from observing. … Closed proceedings, although not absolutely precluded, must be rare and only for cause shown that outweighs the value of openness.”