Claiborne v. Blauser, No. 16-16077 (9th Cir. 2019)
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The Ninth Circuit reversed the district court's denial of a motion for a new trial in a 42 U.S.C. 1983 action brought by a state inmate alleging that he was shackled without justification during his three-day trial on his Eighth Amendment excessive force and deliberate indifference to medical needs claims.
The panel held that the district court abused its discretion in denying a new trial where the inmate's dangerousness and flight risk were central issues at the trial. Therefore, the district court plainly erred in allowing him to be visibly shackled without any showing of a sufficient need for such restraints. The panel remanded and held that the district court had the discretion to impose shackling during the new trial on if it could do so after a full hearing at which the officers showed a compelling need for security and the district court had considered less restrictive alternatives.
Court Description: Prisoner Civil Rights. The panel reversed the district court’s denial of a motion for a new trial and remanded in an action brought pursuant to 42 U.S.C. § 1983 by a convicted state inmate who alleged that he was shackled without justification during his three- day trial on his Eighth Amendment excessive force and deliberate indifference to medical needs claims. The panel first noted that although the inmate did not object to the shackling during trial, he raised the issue in support of his motion for a new trial. The panel applied plain error review. The panel held that because the inmate’s dangerousness and flight risk were central issues at the trial, the district court plainly erred in allowing him to be visibly shackled without any showing of a sufficient need for such restraints. The panel held that on remand, the district court would have discretion to impose shackling during the new trial, but it could only do so after a full hearing at which officers showed a compelling need for security and the court considered any less restrictive alternatives.
The court issued a subsequent related opinion or order on August 14, 2019.
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