State Of Washington v. Jeffery Boatright, 49218-1

Background

Early morning vehicle-prowling incident; Boatright was observed matching a witness description, chased by officers, found hiding with a computer bag containing victims’ property, and charged with felony vehicle prowling in the second degree.
Trial occurred June 27, 2016; on the morning of trial the State sought and the trial court ordered Boatright to wear a mechanical leg‑brace restraint in the courtroom.
The court conducted a brief hearing, cited courtroom size, Boatright’s criminal history and perceived pattern of noncompliance with court orders, and the mandatory five‑year exposure if convicted; it characterized the device as minimally intrusive and not visible to the jury.
Jury convicted Boatright; he received the mandatory 60‑month sentence and appealed, challenging the restraint order on multiple constitutional grounds and raising additional claims in a Statement of Additional Grounds (SAG).
The Court of Appeals held the trial court abused its discretion in ordering the leg brace because the record lacked extraordinary circumstances justifying restraints, but found the error harmless because the jury never saw the device and Boatright showed no impairment in assisting his defense.

Issues

Issue	Boatright's Argument	State's Argument	Held
Trial restraint violated constitutional rights (due process, right to testify, counsel, presumption of innocence)	Leg brace was imposed without "extraordinary circumstances," prejudiced his rights and required reversal	Restraint was minimal, necessary for security given courtroom configuration and defendant’s record; alternatives considered	Court: Imposition was an abuse of discretion—extraordinary circumstances not shown; constitutional claim recognized but discretionary standard not met
Harmlessness of improper shackling	Restraint caused prejudice; warrants new trial	Jury never saw restraint; defendant never reported impairment; any error harmless	Held harmless: no substantial or injurious effect — jury did not see restraint and no demonstrated impairment of defense
SAG: denial of discovery/continuance and right to present a defense	Lack of full discovery (e.g., video) and denial of continuance prevented preparation/presentation	Record defects, counsel said ready; appellant fails to show how any missing materials affected outcome	Not considered under RAP 10.10 (insufficiently developed); no record showing prejudice
SAG: ineffective assistance of counsel (failure to provide discovery, follow client, move to suppress/exclude video, be prepared)	Counsel performed deficiently in multiple respects, affecting outcome	Most complaints lack record support; counsel lodged objections and made strategic choices; no prejudice shown	Ineffective assistance claim fails: appellant did not show deficient performance or a reasonable probability of a different outcome

Key Cases Cited

State v. Turner, 143 Wn.2d 715 (Wash. 2001) (trial court discretion to order restraints reviewed for abuse of discretion)
State v. Hartzog, 96 Wn.2d 383 (Wash. 1981) (restraints permissible only for courtroom safety; broad policy of restraining inmates is improper)
State v. Finch, 137 Wn.2d 792 (Wash. 1999) (defendant entitled to appear free of shackles except in extraordinary circumstances; restraints disfavored)
State v. Damon, 144 Wn.2d 686 (Wash. 2001) (hearing and findings required before permitting restraints)
State v. Hutchinson, 135 Wn.2d 863 (Wash. 1998) (shackling claims subject to harmless error analysis; defendant must show substantial or injurious effect)
State v. Monschke, 133 Wn. App. 313 (Wash. Ct. App. 2006) (prejudice from shackling shown by jury seeing restraints or impairment of defendant’s assistance to counsel)