In Re D.M., 139 A.3d 1073

Victim Nicole DiHart had her cell phone snatched on Pratt Street by a young male on a blue/red BMX bike; she saw his face twice as he looked back while fleeing. Police located a matching bike and detained appellant at a McDonald’s ~2½ hours later; DiHart identified him in a show-up and again at the adjudicatory hearing.
Appellant (a juvenile) was transported to hearings in leg and wrist restraints; defense counsel repeatedly requested removal of shackles during the adjudicatory hearing before the juvenile master, which was denied.
The master denied appellant’s motion to suppress DiHart’s out‑of‑court identification and adjudicated appellant "involved" in theft; appellant filed exceptions to (1) the refusal to remove shackles and (2) denial of the suppression motion.
The circuit court reviewed the record, upheld the master’s rulings, finding the show‑up was not impermissibly suggestive (and identification reliable) and that shackling did not prejudice appellant’s rights.
The Court of Special Appeals affirmed, holding juveniles are presumptively not to be shackled at juvenile hearings absent particularized on‑the‑record findings of security need, but found no reversible prejudice in this case and that the show‑up identification was admissible.

Issue	Appellant's Argument	State's Argument	Held
Shackling at adjudicatory hearing	Shackling violated due process; presumption against visible restraints should apply to juveniles and master made no particularized findings	Court and master had discretion; no rule then required findings; restraints did not impair defense or prejudice proceedings	Juveniles presumptively should not be shackled without on‑the‑record particularized findings, but here no reversible prejudice; judgment affirmed
Admissibility of out‑of‑court (show‑up) ID	Show‑up was impermissibly suggestive and identification should be suppressed	Show‑up was permissible given proximity in time/place and detailed prior description; identification reliable under totality of circumstances	Show‑up admission proper; even if suggestive, identification reliable; denial of suppression affirmed

Deck v. Missouri, 544 U.S. 622 (establishes prohibition on visible physical restraints absent particularized justification)
Holbrook v. Flynn, 475 U.S. 560 (court examines whether courtroom practices are inherently prejudicial to defendant)
Illinois v. Allen, 397 U.S. 337 (disruptive defendant may be restrained, cited limits on preserving courtroom order)
In re Gault, 387 U.S. 1 (juveniles entitled to due process protections, but not all adult procedural rights)
Smiley v. State, 442 Md. 168 (two‑step test for impermissibly suggestive identifications and reliability analysis)
Webster v. State, 299 Md. 581 (factors for evaluating reliability of extrajudicial identifications)
Manson v. Brathwaite, 432 U.S. 98 (reliability, not suggestiveness alone, governs admissibility of eyewitness ID)
Neil v. Biggers, 409 U.S. 188 (sets out factors to weigh reliability of identification)
Turner v. State, 184 Md. App. 175 (discusses permissibility of show‑ups shortly after crimes)