press access and a specific statement in our text by Szypszak (2011, pg. 102) that " The U.S. Supreme Court has instructed that criminal trials historically have been open to the public [and therefore the press] and may be closed only to protect a compelling governmental interest in a manner narrowly tailored to that purpose." Relative to the italicized text, what does this mean and how have we seen it applied in court cases regarding access by the press specifically