STATE v. RAINEY

No. 68846-4-I.

319 P.3d 86 (2014)

STATE of Washington, Respondent, v. Rickey Mitchell RAINEY, Appellant.

Court of Appeals of Washington, Division 1.

February 24, 2014.


Attorney(s) appearing for the Case

Gregory Charles Link , Washington Appellate Project, Seattle, WA, for Appellant.

Prosecuting Atty. King County, Lindsey Megan Grieve , King Co. Pros./App. Unit Supervisor, Seattle, WA, for Respondent.


VERELLEN, J.

¶ 1 During a hearing on Rickey Rainey's motion for a new trial, the trial court closed the courtroom, conducted an in camera review, and concluded that a witness could assert her Fifth Amendment privilege against self-incrimination. The witness did not take the stand or personally assert the privilege in open court before the in camera proceeding occurred and the trial court did not conduct a Bone-Club analysis before closing the courtroom...

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