In Re Pers. Restraint of Coggin (Majority, Concurrence and Dissent)
Annotate this CaseIn this case and in "In re Personal Restraint of Speight,"prospective jurors were questioned in chambers without the trial court engaging in the analysis required by "Washington v. Bone-Club." After his convictions were affirmed on appeal, petitioner William Coggin brought this personal restraint petition, claiming the private questioning of jurors constituted a closure and raising the issue of whether actual and substantial prejudice must be shown from a public trial right violation in order to obtain relief by personal restraint petition. After review, the Supreme Court held that while Coggin's public trial rights were violated, a petitioner claiming a public trial right violation for the first time on collateral review must show actual and substantial prejudice. Coggin did not show actual and substantial prejudice arising from the closure; therefore, his petition was denied.
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