Charles Spikes was convicted of rape and child molestation after a jury found that he sexually assaulted a thirteen-year-old neighbor. During the victim’s testimony, the trial court completely closed the courtroom without conducting the four-part analysis required by Waller v. Georgia. The Georgia Court of Appeals held that the closure was a de facto complete closure implicating the Sixth Amendment public-trial right. The court explained that a trial judge must make specific findings addressing the overriding interest supporting closure, the narrow tailoring of the order, reasonable alternatives, and the closure’s scope and duration. Because the record lacked adequate findings, the error was structural and could not be repaired by a remand for additional findings after the critical testimony had occurred. The court reversed the convictions and ordered a new trial. It concluded that the evidence was sufficient and therefore double jeopardy did not bar retrial.