Does the Public Trial Clause require heightened protection for courtroom access for defendants' family and friends?

QUESTION PRESENTED This Court observed in 1948 that without “exception all courts have held that an accused is at the very least entitled to have his friends, relatives and counsel present.” In re Oliver, 333 U.S. 257, 271-72 (1948). Federal and state appellate courts, citing this passage from Oliver, apply heightened Sixth Amendment protections for the attendance of defendants’ family and friends. The Fourth Circuit is an exception. Alone among the 12 geographic circuits, the Fourth Circuit has never cited this passage from Oliver or acknowledged any special protection for defendants’ friends and family. To this day, the Fourth Circuit is adamant in refusing to address the issue. The district court reduced public seating from 100 to 25 because of security concerns in an eight-defendant drug trafficking trial. It took no action on sworn declarations that security was turning away family and friends. Petitioners emphasized the special role of family and friends in their briefs and at argument. The panel acknowledged the issue at argument. Its published opinion, however, affirmed based on the adequacy of twenty-five “spectators,” going out of its way not to mention who was turned away at the door. Does the Public Trial Clause require heightened protection for courtroom access for defendants’ family and friends ?