State v. Artwell, 177 N.J. 526

Summary

The Supreme Court of New Jersey held that requiring a defense witness to testify in handcuffs without a recorded justification violated the defendant's right to a fair trial. The Court also ruled that defense witnesses may not be required to appear in prison garb because the practice serves no essential state interest. The court reversed the judgment and remanded for a new trial.

Holdings

1. A trial court may require a defense witness to testify in physical restraints only when it has reason to believe restraints are necessary to maintain courtroom security, and the court must hold a hearing or otherwise state on the record, outside the jury's presence, the reasons for the restraint. The trial court's failure to make that record was reversible error.
2. A trial court may not require a defense witness to appear at trial in distinctive prison garb. Defense witnesses who are incarcerated should generally be provided civilian clothing, and the defendant need not make an affirmative request for civilian clothing.

Questions Presented

1. Whether requiring a defense witness to testify before the jury in handcuffs without stating reasons on the record violated the defendant's right to a fair trial.
2. Whether requiring a defense witness to testify in distinctive prison garb violated the defendant's right to a fair trial.
3. Whether the trial court's errors were harmless or required reversal and a new trial.

Disposition

reversed_and_remanded