In the 1986 Riverside Press?Enterprise v. Superior Court case (Press-Enterprise II), the Supreme Court held that:

a) preliminary hearings may be closed to the public whenever there is a “reasonable likelihood” that prejudicial publicity would result from an open hearing; b) preliminary hearings may be closed to the public only when there is a “substantial probability” that an open hearing would produce prejudicial publicity and closing the hearing would actually prevent the publicity; c) preliminary hearings must be closed to the public whenever the defendant requests it; d) preliminary hearings may not ever be closed to the public; e) jury selection must normally be open to the press and public.

B