State v. Mills
In State v. Mills, 196 Ariz. 269, 272, P13, 995 P.2d 705, 708 (App. 2000) the trial court precluded the use of handcuffs or shackles during trial, but did not preclude other restraints.
As a result, and without objection, the defendant was restrained by a leg brace underneath his clothes.
On appeal, the Court found that the defendant had waived the issue by failing to object, and stated that if the defendant was restrained by a device that could not be seen, the "unseen 'restraint could not have affected the presumption of innocence.'" Id. at 272-73, 995 P.2d at 708-09.
More importantly, the Court noted that if the defendant had "made a proper objection at trial . . . the state would have been required to establish 'some reason' for the restraint in the courtroom." Mills, 196 Ariz. at 273, P15, 995 P.2d at 709.