The First Amendment right of access to trial proceedings is of far more recent vintage than constitutional limitations on prior restraints and subsequent punishments. Although courts have long recognized some form of common law right to attend criminal trials, the U.S. Supreme Court did not declare a constitutional right to be present at trials until 1980. The Court subsequently extended that right to other proceedings, including voir dire and pretrial hearings. The right to attend is not absolute, however. The press and public may still be excluded, provided the trial court applies a heightened scrutiny analysis to protect the First Amendment interests at stake.