Bell v. Texas (Original)

Defendant Vaughn Bell contended the court of appeals erred in finding the trial judge's error that ordered him shackled during trial was harmless. Over a lunch break during the guilt phase of Bell's trial for the offense of possession of a controlled substance, the judge ordered Bell shackled. Accordingly, Bell was shackled with cuffs and "a chain that is linked between his two ankles." Bell objected to the shackling, arguing that using the device in front of the jury, if seen, would deprive him a presumption of innocence, fair trial, "and his rights under United States and Texas Constitution." The State responded by asking the judge to have the court's bailiff sit in various seats in the jury box to see if jurors would be able to see Bell's shackles. Complying, the bailiff told the judge that he could not see the chain or ankle cuffs. Bell countered that the jury would be able to hear the chains rattle if Bell moved during the trial. The judge overruled Bell's objection. Upon review, the Supreme Court concluded the trial court erred in shackling Bell, but that the error was not constitutional error because there was no evidence the jury saw his restraints. Despite the court of appeals' erroneous application of a constitutional-error harm analysis, the Court affirmed its judgment.