The exclusion of The Roanoke Times newspaper from a competency hearing and access to documents submitted for that hearing violated the First Amendment guarantee of freedom of the press and the Virginia state constitution.

Earl Bramblett was charged with murdering a family of four. He raised the insanity defense and requested the trial court order the competency hearing closed to the public, including the media. He successfully argued that the evidence presented at the hearing was not likely to be admitted at his later trial, and his right to a fair trial would be prejudiced. He also claimed the nature of his case was such that a voir dire was an inadequate method of producing an impartial jury.

The trial judge agreed, adding that Bramblett's physician-patient privilege would be compromised by press access to a hearing about confidential information. The publisher immediately appealed and the Appeals Court ordered the trial court to videotape the hearing pending resolution of the publisher's petition for a writ of mandamus. The newspaper sought access to the videotape as well as documents submitted to the court.