Some interesting points from the COA ruling:
"After considering the State’s objection, the court conducted the Waller analysis and determined that completely closing the proceeding to the public was not necessary. The court suggested that the press and public be moved to the overflow courtroom to view the trial. Arias was advised of the ruling, and Arias subsequently advised the court that she would not testify if the press and public could know how she testified “because of the pressure that I would feel because of these threats.” Although expressing concern that Arias was being manipulative, the court stated it had considered the potential legal ramifications if an appellate court later determined that Arias did not voluntarily waive her right to present evidence in mitigation. As a result, the court closed the proceeding for Arias’ testimony."
"However, even if Arias decides not to testify in open court, her lawyers or the State can present evidence from the guilt phase trial or the earlier
penalty phase trial that could be considered to be mitigation.2 A defendant who testified in open court during the guilt phase of the trial cannot decide she will only testify in the penalty phase if the press and public are excluded and her testimony is sealed until after any verdict. Neither the rule nor case law envisions that her concerns amount to a clear and present danger to a fair trial before an impartial jury."