State v. Franklin

In State v. Franklin, 97 Ohio St.3d 1, 2002 Ohio 5304, 776 N.E.2d 26, the high court encouraged trial courts to hold a hearing prior to handcuffing a defendant at any phase of trial. Id. at P82. The high court, however, declined to pronounce an "absolute rule" requiring such a hearing. Id. Instead, the court noted that "where the facts and circumstances surrounding a defendant illustrate a compelling need to impose exceptional security procedures, the trial court's exercise of discretion in this regard should not be disturbed unless its actions are not supported by the evidence before it." Id.