Davenport v. MacLaren, No. 17-2267 (6th Cir. 2020)
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Davenport, convicted of first-degree murder after a jury trial in Michigan state court. He was visibly shackled at the waist, wrist, and ankles during trial. Davenport’s right hand was uncuffed and there was a privacy curtain around the defense table. The court did not justify the shackling on the record. During an evidentiary hearing on direct appeal, several jurors recalled that they had thought Davenport might be dangerous when they saw him in shackles. The jurors testified that Davenport’s shackling was not discussed during deliberations and did not affect their verdict. After exhausting his state remedies, Davenport challenged his conviction in a habeas corpus petition under 28 U.S.C. 2254. The district court found that the shackling was harmless error and denied the petition.
The Sixth Circuit reversed and granted a conditional writ. Because “shackling is ‘inherently prejudicial,’” and the evidence of premeditation and deliberation necessary to a first-degree murder conviction was not overwhelming, the state has not met its burden to show the restraints did not have a “substantial and injurious effect or influence in determining the jury’s verdict.”
The court issued a subsequent related opinion or order on September 15, 2020.
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