In Presley v. Georgia (2010) U.S. 130 S.Ct. 721, the trial court barred the defendant's uncle from the courtroom during voir dire because there was insufficient room for him until after the jury was seated. (Presley, at p. 130 S.Ct. at p. 722.) The defendant then challenged his conviction on the ground that he had been denied his Sixth Amendment right to a public trial. (Presley, at p. 130 S.Ct. at p. 723.) Though it analyzed the issue under the Sixth Amendment, the court also observed that "the public trial right extends beyond the accused and can be invoked under the First Amendment." (Ibid.) In reversing the defendant's conviction, the court acknowledged that "there are no doubt circumstances where a judge could conclude that threats of improper communications with juror or safety concerns are concrete enough to warrant closing voir dire. But in those cases, the particular interest, and threat to that interest, must 'be articulated along with findings specific enough that a reviewing court can determine whether the closure was properly entered.' " (Presley, at p. 130 S.Ct. at p. 725.)