Although the scrutiny structure has only developed in the last 50 years or so, concern about the effects of publicity on the rights of criminal defendants is not new. As long ago as the 1807 trial of Aaron Burr, the legal system has worried that widespread publicity could have detrimental effects on trials, especially by predisposing jurors to accept media versions of events. In the Burr case, "defense counsel urged that jurors had been prejudiced against Colonel Burr by inflammatory articles carried in the Alexandria Expositor and other newspapers."1