Jessie J. Barnes v. Donald Uhler, Superintendent, Upstate Correctional Facility, et al.

The Fifth Amendment’s Due Process Clause forbids courts from requiring litigants to be physically restrained during a jury trial in the absence of a special need. In Deck v. Missouri, 544 U.S. 622 (2005), this Court reiterated that a trial court may order a litigant to be physically restrained only after determining that restraints serve an essential state interest particular to that trial and are a measure of last resort. In 2022, Petitioner Jessie J. Barnes was forced to wear shackles during the trial of his civil rights claims against corrections officers who had severely beaten him, leaving him with a fractured leg and a severed finger. At the beginning of the trial, the judge solicited a correctional officer’s “instructions” on how Mr. Barnes should be retrained. Without giving any reasons, the officer recommended leg shackles. The court adopted the recommendation, without giving any substantive reasons of its own, let alone any justification specific to Mr. Barnes. The Second Circuit affirmed the trial court’s decision. The question presented is: Whether the Deck test allows a trial judge to require a litigant to wear physical restraints during a jury trial without stating on the record the case-specific state interests or reasons justifying such restraints, as long as the judge concludes that the order is based on his or her independent judgment, as the Second and Fifth Circuits have held, or whether the trial court must instead enumerate the essential state interests justifying the restraints, as the Sixth Circuit, Ninth Circuit, and several state high courts have held.