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Estelle v. Williams

    Brief Fact Summary. An individual murdered his ex-landlord with a knife. While awaiting trial in jail, he asked an officer for his civilian clothing, but instead was required to wear his prison issued clothing during trial.

    Synopsis of Rule of Law. “[A]lthough the State cannot, consistently with the Fourteenth Amendment, compel an accused to stand trial before a jury while dressed in identifiable prison clothes, the failure to make an objection to the court as to being tried in such clothes, for whatever reason, is sufficient to negate the presence of compulsion necessary to establish a constitutional violation.”

    Facts. The Respondent, Williams (the “Respondent”), was convicted in state court for assault with intent to commit murder with malice. The Respondent went back to an apartment complex he used to live in and got into an altercation with his ex-landlord. The Respondent eventually stabbed the landlord.
    The Respondent could not post bond and he was held in custody while awaiting trial. After he learned he was to go on trial, the Respondent asked an officer for his civilian clothes. This request was denied. As such, the Respondent appeared at trial with prison issued clothing. No objection was raised at trial
    The Respondent was found guilty and the Texas Court of Criminal Appeals affirmed the conviction. The Respondent then sought release in the United States District Court on a petition for a writ of habeus corpus. The District Court held that it was harmless error to force plaintiff to wear prison issued clothing. The Fifth Circuit found it was not harmless error.

    Issue. “[W]hether an accused who is compelled to wear identifiable prison clothing at his trial by a jury is denied due process or equal protection of the laws?”

    Held. “The potential effects of presenting an accused before the jury in prison attire need not, however, be measured in the abstract. Courts have, with few exceptions, determined that an accused should not be compelled to go to trial in prison or jail clothing because of the possible impairment of the presumption so basic to the adversary system. This is a recognition that the constant reminder of the accused’s condition implicit in such distinctive, identifiable attire may affect a juror’s judgment. The defendant’s clothing is so likely to be a continuing influence throughout the trial that, not unlike placing a jury in the custody of deputy sheriffs who were also witnesses for the prosecution, an unacceptable risk is presented of impermissible factors coming into play.”
    “Unlike physical restraints, permitted [in another case] compelling an accused to wear jail clothing furthers no essential state policy. That it may be more convenient for jail administrators, a factor quite unlike the substantial need to impose physical restraints upon contumacious defendants, provides no justification for the practice. Indeed, the State of Texas asserts no interest whatever in maintaining this procedure.”
    “Similarly troubling is the fact that compelling the accused to stand trial in jail garb operates usually against only those who cannot post bail prior to trial. Persons who can secure release are not subjected to this condition. To impose the condition on one category of defendants, over objection, would be repugnant to the concept of equal justice embodied in the Fourteenth Amendment.”
    “Courts [also] have required an accused to object to being tried in jail garments, just as he must invoke or abandon other rights.” Here, “[t]he record is clear that no objection was made to the trial judge concerning the jail attire either before or at any time during the trial. This omission plainly did not result from any lack of appreciation of the issue, for respondent had raised the question with the jail attendant prior to trial. At trial, defense counsel expressly referred to respondent’s attire during voir dire. The trial judge was thus informed that respondent’s counsel was fully conscious of the situation.”
    “Nothing


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