Waller v. Georgia - Significance

On one level, Waller v. Georgia involved Sixth Amendment issues. However, as Justice Powell stated in the unanimous opinion, the Court had "not recently" considered a Sixth Amendment case, and instead it turned to recent rulings with regard to reporting of trial proceedings--a concern more properly addressed under the First Amendment. Waller thus further established and solidified the tests developed by the Court earlier in the 1984 term, in its Press-Enterprise Co. v. Superior Court of California decision. The latter defined the limits of the government's power to suppress trial proceedings on the one hand, and of the public's right to know on the other. Both cases belonged to a larger trend in the 1980s toward allowing the public as much knowledge of trial proceedings as was constitutionally possible.