Rochelle, who attempted to approach Cosby as he and his lawyers entered the court, had drawn the phrases "Women's Lives Matter", "Cosby rapist" and "#MeToo" on her body, as well as the names of Cosby's victims.
According to media reports the 39-year-old actress appeared in a number of episodes of Cosby's most successful television series, The Cosby Show.
Actress Nicolle Rochelle, who worked on one of Bill Cosby's shows, was detained.
Photo: AP
Rochelle was detained by police and charged with disorderly conduct.
"The main goal was to make Cosby uncomfortable because that is exactly what he has been doing for decades to women and to show him that the body can be aggressive and empowered," she said later.
A statement from the county later noted that if Rochelle is found guilty she would be given a fine and required to pay court costs.
The particular complexity of this Cosby trial is that much of it pivots on the individual recollections of the parties involved; according to media reports there is no meaningful forensive evidence to be presented.
Constand claims Cosby drugged and assaulted her in 2004; Cosby claims he and Constand had a consensual sexual relationship.
Constand reported the incident to police a year later but no charges were laid at the time, with the police citing a lack of evidence. Constand then sued Cosby in civil court and the parties settled in 2006.
The terms of that settlement are sealed.
Nicolle Rochelle is taken away after protesting outside Bill Cosby's trial.
Photo: AP
The original Constand civil case is significant in the wider context of the more than 50 women who have come forward in the last decade to claim Cosby had assaulted them.
A portion of Cosby's deposition from that case, unsealed in 2015, included a statement from Cosby in which he acknowledged acquiring drugs to give to women he sought for sex.
Cosby did not admit to any criminal activity in the deposition.
US district judge Eduardo Robreno ordered the records unsealed in 2015 following a request from the Associated Press.
Bill Cosby arrives for the first day of his retrial as police detain a protester nearby.
Photo: Associated Press
Robreno noted at the time that because Cosby had "donned the mantle of public moralist and mounted the proverbial electronic or print soap box to volunteer his views on, among other things, childrearing, family life, education, and crime" he had "voluntarily narrowed the zone of privacy that he is entitled to claim."
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Out of the more than 50 women who have come forward to make claims of sexual harassment and assault against Cosby, the Constand case is the only one which has made it to the trial stage.
Both sides of the case are returning to the courtroom with additional firepower, according to reports.
In the original trial, prosectutors were permitted to seek testimony from a witness who claimed Cosby had drugged and assaulted her; in the retrial they will be allowed to seek testimony from up to five women making those claims.
Cosby, meanwhile, has retained a new legal team led by Tom Mesereau, the high-profile Los Angeles lawyer who defended Michael Jackson against child molestation accusations in a 2005 trial.
That trial ended with Jackson acquitted of all 14 charges against him.
Cosby faces three counts of aggravated indecent assault, each punishable by up to 10 years in prison.
The 80-year-old comedian has pleaded not guilty to the charges.
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Michael Idato is a Senior Writer based in Los Angeles for The Sydney Morning Herald.
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