What constitutes a "closure" within the meaning of the Sixth Amendment?

The People argue that there was no "closure" within the meaning of the Sixth Amendment because limiting access to a courtroom is within the trial court's discretion. The People cite to several cases, including United States v. Shryock, 342 F.3d 948 (9th Cir.2003) and People v. Colon, 71 N.Y.2d 410, 526 N.Y.S.2d 932, 521 N.E.2d 1075 (1988), arguing that they support the proposition that a "closure" does not occur when the trial court places limitations on how many people can enter the courtroom. The cases cited by the People stand for the limited proposition that no single member of the public has a right to gain admittance to a courtroom if there is no available seat. That is, so long as the public at-large is admitted to the proceedings, the Sixth Amendment does not guarantee access to unlimited numbers; the fact that a particular individual is not admitted does not constitute a violation of the Constitution.

[555 F.3d 117]