People v. Billie, 10 Cal. App. 5th 434

Defendant Robert Lee Billie was charged with attempted murder (count 1) and assault with a deadly weapon (count 2) arising from a May 16, 2013 stabbing; the jury deadlocked on count 1, convicted on count 2, and the prosecution dismissed count 1.
Special allegations included personal infliction of great bodily injury and personal use of a deadly weapon; prior serious-felony and prior-prison-term enhancements were found true, and defendant received a 16-year sentence.
Billie represented himself at trial with advisory counsel, waived a jury on the prior-conviction phase, and bifurcated proceedings.
While incarcerated pretrial, Billie had documented violent incidents and disciplinary violations (including possession of razors and assaults on inmates); he also had a prior 2004 conviction for stabbing another man that punctured a lung.
The trial court ordered Billie to wear leg shackles and one hand cuff during trial, took steps to obscure the restraints from jurors, and instructed the jury to disregard the restraints as evidence.
The court also admitted evidence of the 2004 uncharged stabbing to prove intent; the court later found any possible error harmless given the strength of the evidence against Billie.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court properly ordered physical restraints in jury's presence	Restraints were justified by defendant's documented violent history and jail misconduct, and court used least-intrusive measures	Restraints violated due process and fair-trial rights of self-represented defendant	Affirmed — trial court did not abuse discretion; manifest need shown and precautions minimized prejudice
Whether trial court erred in admitting prior 2004 assault to prove intent	Prior stabbing was admissible under Evid. Code §1101(b) to show intent/motive for current stabbing	Admission was improper and prejudicial; defendant contended prior incident required same motive/self-defense showing	Affirmed — even if error, admission was harmless given overwhelming evidence of guilt

Faretta v. California, 422 U.S. 806 (1975) (criminal defendant has right to self-representation)
People v. Lewis and Oliver, 39 Cal.4th 970 (2006) (restraints may be used on showing of manifest need; no formal hearing required)
People v. Combs, 34 Cal.4th 821 (2004) (trial court duty to maintain orderly proceedings and safety)
People v. Wallace, 44 Cal.4th 1032 (2008) (use of concealed restraints justified by jailhouse violence and weapons possession)
People v. Ewoldt, 7 Cal.4th 380 (1994) (standards for admitting prior misconduct for noncharacter purposes)
People v. Kipp, 18 Cal.4th 349 (1998) (degree of similarity required for intent inference is low)
People v. Simon, 184 Cal.App.3d 125 (1986) (analysis of similarity and motive for admitting prior acts)
People v. Thomas, 52 Cal.4th 336 (2011) (harmlessness of admitting prior uncharged assault evidence)
People v. Foster, 50 Cal.4th 1301 (2010) (harmless-error analysis when prior crimes evidence admitted)