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STATE v. RAINEY

No. 68846-4-I.

327 P.3d 56 (2014)

180 Wn. App. 830

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

Court of Appeals of Washington, Division 1.

April 28, 2014.

Attorney(s) appearing for the Case

James Morrissey Whisman , Lindsey Megan Grieve , King County Prosecutor's Office, Prosecuting Atty King County, King Co. Pros/App Unit Supervisor, Seattle, WA, for Respondent.

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

VERELLEN, A.C.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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