State v. Rollins, 231 N.C. App. 451 (Dec. 17, 2013)

The trial court did not err on remand when it conducted a retrospective hearing to determine whether closure of the courtroom during the victim’s testimony was proper under Waller v. Georgia and decided that question in the affirmative. The court rejected the defendant’s argument that the trial court’s findings of fact had to be based solely on evidence presented prior to the State’s motion for closure; it also determined that the evidence supported the trial court’s factual findings.