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3rd DCAApril 15, 2026Affirmed🔬 Novel Issue

Cordon v. State

Case No. 3D2023-1858

The Third DCA affirmed a conviction for sexual battery on a minor, rejecting the defendant's claim that excluding his teenage biological daughter (the victim's half-sister) from the courtroom during the victim's testimony violated his Sixth Amendment and Florida constitutional right to a public trial. The court held that the trial court properly applied the Waller v. Georgia four-factor test in ordering a narrowly tailored, temporary partial closure, and that section 918.16(2), Florida Statutes, which requires courts to permit certain categories of persons (like immediate family) to remain during a partial closure, does not create an absolute right for those exempted individuals to stay regardless of case-specific concerns.

Key facts

  • Defendant was convicted of sexual battery on a minor victim; the victim's half-sister (defendant's teenage biological daughter) was excluded from the courtroom during the victim's testimony.
  • Defendant appealed, claiming the courtroom closure violated his Sixth Amendment and Florida constitutional rights to a public trial.
  • +2 more key facts with a free trial

Why it matters

This opinion is useful to practitioners litigating courtroom closure and public trial issues in sexual offense cases, particularly where the defense argues that section 918.16(2)'s list of exempted persons (family… — full analysis with a trial

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