Eustice v. State
In Eustice v. State, 11 P.3d 897 (Wyo. 2000), the jury briefly observed the defendant in handcuffs and shackles in the hallway as he was being returned to the courtroom following a break in the trial.
The Court affirmed the defendant's conviction on the ground that a jury's brief or incidental viewing of the defendant in restraints is not necessarily prejudicial, and there had been no showing of actual prejudice. Id. at 901.
The Court further concluded that defense counsel was not ineffective for having failed to move for a mistrial. Such a motion would have been futile because there was no inherent prejudice. Id. at 905.