1. The State is correct that the Supreme Court has yet to consider the issue of whether and when a trial court, consistent with constitutional protections, may order a defendant to wear a stun belt during his trial. However, the Supreme Court has decided a series of cases over the past forty years that clearly establish the proposition that a trial court may not impose a physical restraint upon a defendant’s person without an individualized finding of dangerousness or risk of escape. See, e.g., Holbrook v. Flynn, 475 U.S. 560, 568-69, 106 S.Ct. 1340, 89 L.Ed.2d 525 (1986) (noting that shackling is “inherently prejudicial” and is only “justified by an essential state interest specific to each trial”); Illinois v. Allen, 397 U.S. 337, 343-44, 90 S.Ct. 1057, 25 L.Ed.2d 353 (1970) (<HOLDING>). The Supreme Court most recently reaffirmed
holding that no person should be tried while shackled and gagged except as a last resort but that such measures are allowed if the defendant is disruptive contumacious and stubbornly defiant holding that a plaintiff should be allowed to amend the complaint to add a claim holding that burglary may qualify as offense against person if as committed it is in fact a crime against a person holding that a defendant is entitled to be tried by 12 not 9 or even 10 impartial and unprejudiced jurors holding that a communication between the judge and juror which is unrelated to the case being tried is not improper and prejudicial