Does an undercover officer's interest in potentially continuing undercover work in the general area where a defendant's family members reside categorically override the defendant's Sixth Amendment right to a public trial?

QUESTION PRESENTED Defendants have a fundamental right to a public trial under the Sixth Amendment. See Waller v. Georgia, 467 U.S. 39, 45 (1984). To protect that important right, this Court has fashioned a demanding test to ensure that any courtroom closures are a “rare” exception—not the rule. See id. Over time, however, New York courts have deviated from the Court’s standard in Waller and established a de facto rule that permits closing the courtroom whenever the witness is an undercover officer and that officer may have ongoing undercover work in the geographical area where a defendant’s family members (or members of the public) reside. This rule creates a categorical exception to the Sixth Amendment right to a public trial, which is neither contemplated in the plain language of the amendment nor this Court’s jurisprudence. The Question Presented is: Does an undercover officer’s interest in potentially continuing undercover work in the general area where a defendant’s family members reside categorically override the defendant’s Sixth Amendment right to a public trial? i