State v. Simplot
In State v. Simplot, 180 Wis. 2d 383, 409, 509 N.W.2d 338 (Ct. App. 1993), defendants were shackled in the courtroom during their trial because they had been charged "with substantial, serious crimes which involved the use of weapons." Id.
There was no evidence that the shackles were visible to the jury. See id.
The Court upheld the use of restraints because the trial court had stated its reasons and these reasons "did not exceed the bounds of its discretion." Id.