Does the need for judicial efficiency trump the right to exclude members of the public from the courtroom?

"New York", United States of America

The following excerpt is from People v. Martin, 16 N.Y.3d 607, 2011 N.Y. Slip Op. 03885, 925 N.Y.S.2d 400, 949 N.E.2d 491 (N.Y. 2011):

Neither does the need for judicial efficiency and the conservation of judicial resources trump this constitutional right. While the trial court does have an inherent power, at its discretion, to monitor admittance to the courtroom, as the circumstances require, in order to prevent overcrowding [or] to accommodate limited seating capacity, such power does not extend to excluding specific members of the public from the courtroom ( People v. Colon, 71 N.Y.2d 410, 416, 526 N.Y.S.2d 932, 521 N.E.2d 1075 [1988] ).

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