Summary
The Ninth Circuit held that a district court plainly erred by allowing a state inmate to be visibly shackled during his § 1983 trial on Eighth Amendment excessive force and deliberate indifference claims without any showing of a compelling security need. Because the inmate's dangerousness and flight risk were central issues, the shackling prejudiced his right to a fair trial, requiring reversal of the denial of his motion for a new trial. The court also clarified that a district court may not rely solely on a litigant's status as a convicted felon to justify restraints, and must conduct an individualized hearing considering less restrictive alternatives before imposing shackling in civil proceedings.
Holdings
- The district court plainly erred in allowing Claiborne to be visibly shackled without any showing of a sufficient need for such restraints, because his dangerousness and flight risk were central issues at trial.
Questions Presented
- Whether the district court erred in denying Claiborne's motion for a new trial based on the unjustified shackling during his civil trial.
Disposition
reversed_and_remanded
Cases Cited (12)
- Deck v. Missouri, 544 U.S. 622 (2005)(positive)
- Tyars v. Finner, 709 F.2d 1274 (9th Cir. 1983)(positive)
- Duckett v. Godinez, 67 F.3d 734 (9th Cir. 1995)(positive)
- Lemons v. Skidmore, 985 F.2d 354 (7th Cir. 1993)(positive)
- Holloway v. Alexander, 957 F.2d 529 (8th Cir. 1992)(positive)
- Davidson v. Riley, 44 F.3d 1118 (2d Cir. 1995)(positive)
- Sides v. Cherry, 609 F.3d 576 (3d Cir. 2010)(positive)
- Hudson v. McMillian, 503 U.S. 1 (1992)(positive)
- McKinney v. Anderson, 924 F.2d 1500 (9th Cir. 1991)(positive)
- Gorton v. Todd, 793 F. Supp. 2d 1171 (E.D. Cal. 2011)(positive)
Showing top 10 of 12.
Cited In (0)
No citing cases on record yet.