Kenneth Dwayne Vaughn v. State of Indiana, 971 N.E.2d 63

Defendant Vaughn vacillated between pro se and court-appointed counsel throughout the trial.
The trial court repeatedly instructed Vaughn to stop speaking; the bailiff briefly covered Vaughn’s mouth to quiet him.
Vaughn testified after a long dispute over trial strategy and counsel’s role, with accompanying interruptions.
Defense counsel moved for mistrial after Vaughn testified while restrained in front of the jury; the court denied.
Appeals court reversed, holding abuse of discretion; Supreme Court granted transfer and affirmed denying mistrial, finding no actual harm to Vaughn.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the bailiff’s brief restraint of Vaughn violated his right to a fair trial.	Vaughn’s behavior and restraint could prejudice the jury.	Any restraint created error requiring mistrial.	No actual harm; mistrial not required.
Whether Vaughn suffered actual harm from the restraint so as to warrant reversal.	Harm occurred by restraining him in front of jury.	Minimal, brief incident; no prejudice.	No actual harm; trial court did not abuse discretion.

Illinois v. Allen, 397 U.S. 337 (U.S. 1970) (defendant may be restrained to maintain order; need not reward disruptive conduct)
Avant v. State, 528 N.E.2d 74 (Ind. 1988) (defendant’s own actions can justify extreme remedies to maintain trial integrity)
Mengon v. State, 505 N.E.2d 788 (Ind. 1987) (trial court duty to maintain order in courtroom)
Kocielko v. State, 938 N.E.2d 243 (Ind. Ct. App. 2010) (restraints in front of jury require record of reasons; harm must be shown)
Bedwell v. State, 481 N.E.2d 1090 (Ind. 1985) (mistrial warranted only when no other remedy could cure the situation)