The Pennsylvania Superior Court has held that a trial court must consider the public's right of access to a preliminary hearing before ordering closure.
In re Petition of the Daily Item, __ Pa. Super. ___, 456 A.2d 580 (1983).
Charles J. Porter,
Constitutional Law - First Amendment - Closures of a Preliminary Hearing - Public Right of Access,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol23/iss1/13