While refraining from formally overruling Estes v. Texas, which in 1965 held that media coverage was "infringing the fundamental right to a fair trial guaranteed by the Due Process Clause of the Fourteenth Amendment," it effectively did so.

[1] In an 8-0 decision in favor of the State of Florida, Chief Justice Burger wrote the opinion for the Supreme Court.

Citing Estes v. Texas (1964), the Court denied Chandler's claim that a media presence in the courtroom is offensive to due process.

So long as the "evolving technology" does not infringe on "fundamental guarantees" of the accused, the media does not violate a person's constitutional right to due process.

Further, the Court noted that the previous statute upheld by the Florida State Supreme Court implemented strict guidelines "intended to protect the right of a defendant to a fair trial" in regards to the medias coverage of a criminal trial.