JEFFREY MICHAEL SHIFLETT v. STATE OF MARYLAND
Court of Special Appeals, Nazarian, Sept. 28, 2016,
6th Amendment – Trial Restraint – Giving an unruly defendant the choice of wearing an ankle bracelet that delivers a stun if activated or not participating in his trial was not inappropriate in light of his demeanor
Apparently Baltimore County has stun cuffs and a policy with regard to their use that dates back to 2011. Also interesting that the sheriffs were going with stun-cuffs or nothing.
History: Defendant obsessed over, threatened, and then killed his ex-co-defendant. Prior to trial, Defendant wrote “thoroughly inappropriate and venomously vulgar” letters to the judge at home, attempted to enter the judge’s chambers before trial, fought and spat at sheriff’s deputies, and was otherwise disruptive.
The Court declined to consider whether use of a lesser restraint, such as the more common leg shackles, would have sufficed. We need not determine “whether less stringent security measures were available to the trial court, but whether the measures applied were reasonable, and whether they posed an unacceptable risk of prejudice to the defendant.”