Prior to the U.S. Supreme Court decision in Richmond Newspapers, Inc. v. Virginia, constitutional rights to access remained an untapped resource that the public and the press might have used to gather government-held information. The right of access to criminal trials will probably prove only a prelude to a wide-ranging debate over the proper extent of this newly recognized right. If a broad, structural view of the first amendment is adopted, then the constitutional right of access could have a tremendous impact on the relationship between the government and the press. If a narrow view is adopted, such as the historical momentum approach suggested by Chief Justice Burger in Richmond Newspapers, then the constitutional right will be quite narrowly applied. It is over contexts such as private executions that the battle between the differing constitutional interpretations will be fought. Private executions demonstrate the widely divergent results that can be achieved by these contrasting constitutional theories. A constitutional right of access would declare several State statutes unconstitutional and might require the formulation of administrative guidelines admitting press representatives in other States. If a right of access does not exist, the private execution statutes will be immune from first amendment attacks and subject only to rather feeble equal protection claims. An acceptable State law should probably allow limited press access to the execution without permitting the use of recording devices. A total of 168 case notes are supplied. (Author summary modified)