When Defense Counsel errs by not objecting to an improper courtroom closure, should reviewing courts apply a 'fundamental unfairness' test, or the traditional test (reasonable probability of a different outcome) when analyzing prejudice under the second prong of Strickland v. Washington, 466 U.S. 668 (1984)?

QUESTION PRESENTED When Defense Counsel errs by not objecting to an improper courtroom closure, should reviewing courts apply a “fundamental unfairness” test, or the traditional test (reasonable probability of a different outcome) when analyzing prejudice under the second prong of Strickland v. Washington, 466 U.S. 668 (1984)? ii PARTIES TO PROCEEDING AND RELATED CASES There is no parent or publicly held company owning 10% or more of the corporation’s stock involved in this case. Rules 14.1(b)(ii) and 29.6. A list of all proceedings in other courts that are directly related to the case appear below. Rule 14.1(b)Gii). ¢ §©State v. Alexander, No. 14-CR-487 (Ga.Super. June 25, 2019). e Alexander v. State, 356 Ga. App. 392 (2020). e Alexander v. State, 313 Ga. 521 (2022).