Holbrook v. Flynn (1986) 475 U.S. 560 rejected a challenge to four uniformed state troopers sitting in the first row of the spectators' section during the trial. The court reiterated the principle that a defendant is entitled to have guilt determined solely on the basis of evidence introduced at trial, then explained: This does not mean, however, that every practice tending to single out the accused from everyone else in the courtroom must be struck down. Recognizing that jurors are quite aware that the defendant appearing before them did not arrive there by choice or happenstance, we have never tried, and could never hope, to eliminate from trial procedures every reminder that the State has chosen to marshal its resources against a defendant to punish him for allegedly criminal conduct. To guarantee a defendant's due process rights under ordinary circumstances, our legal system has instead placed primary reliance on the adversary system and the presumption of innocence. When defense counsel vigorously represents his client's interests and the trial judge assiduously works to impress jurors with the need to presume the defendant's innocence, we have trusted that a fair result can be obtained." (Holbrook, supra, 475 U.S. at pp. 567-568.) Holbrook held that "the conspicuous, or at least noticeable, deployment of security personnel in a courtroom during trial" is not "the sort of inherently prejudicial practice that, like shackling, should be permitted only where justified by an essential state interest specific to each trial." (Holbrook, at pp. 568-569.) "The chief feature that distinguishes the use of identifiable security officers from courtroom practices we might find inherently prejudicial is the wider range of inferences that a juror might reasonably draw from the officers' presence. While shackling and prison clothes are unmistakable indications of the need to separate a defendant from the community at large, the presence of guards at a defendant's trial need not be interpreted as a sign that he is particularly dangerous or culpable. Jurors may just as easily believe that the officers are there to guard against disruptions emanating from outside the courtroom or to ensure that tense courtroom exchanges do not erupt into violence. Indeed, it is entirely possible that jurors will not infer anything at all from the presence of the guards. If they are placed at some distance from the accused, security officers may well be perceived more as elements of an impressive drama than as reminders of the defendant's special status. Our society has become inured to the presence of armed guards in most public places; they are doubtless taken for granted so long as their numbers or weaponry do not suggest particular official concern or alarm." (Holbrook, supra, 475 U.S. at p. 569.) Holbrook concluded that cases involving courtroom security measures should be reviewed on a case-by-case basis rather than pursuant to a "presumption that any use of identifiable security guards in the courtroom is inherently prejudicial." (Holbrook, supra, 475 U.S. at p. 569.) The court declined to find an unacceptable risk of prejudice in the spectacle of four such officers quietly sitting in the first row of a courtroom's spectator section," because it was "unlikely to have been taken as a sign of anything other than a normal official concern for the safety and order of the proceedings," particularly as the case involved six defendants. (Id. at p. 571.) In sum, the trial court permitted the seating of four uniformed state troopers "in the first row of the spectators' section" of the courtroom during the trial of six in-custody defendants accused of breaking into safe deposit boxes and escaping with several million dollars. (Holbrook, supra, 475 U.S. at pp. 562, 565.) The court found this action not "inherently prejudicial," in the process distinguishing cases involving the shackling or binding of a defendant. It held that "'reason, principle, and common human experience,' counsel against a presumption that any use of identifiable security guards in the courtroom is inherently prejudicial." (Id. at p. 569.)