The Sixth Amendment right to a public trial enjoys a rich historical heritage and occupies a special place in the hierarchy of constitutional protections, as the Supreme Court continues to recognize it as one of a “very limited class” of rights subject to structural error treatment. Nonetheless, lower courts regularly undermine the public trial right by manipulating the definition of courtroom closure required for Sixth Amendment claims. Three splits have emerged among lower courts on the constitutional meaning of “closure”: i) whether a defendant must demonstrate that a specific person was excluded from the courtroom, ii) whether a temporary closure can be too trivial to trigger Sixth Amendment concerns, and iii) whether the exclusion of a select group of spectators (dubbed a “partial closure”) warrants reversal as structural error. This Note explores these splits and their consequences—the creation, in effect, of distinct strong and weak forms of the constitutional public trial right. Part I discusses the historical origins of the public trial right and its treatment by the Court in recent decades. Part II examines the trifecta of splits related to this right and assesses the reasoning that has led to the courts’ divergent conclusions. Finally, Part III proposes a resolution to the conflicts through the use of the Supreme Court’s balancing test for analyzing closures, laid out in Waller v. Georgia. This test adequately respects the right to an open trial while acknowledging the need for efficient and consistent judicial administration.