State v. Timothy Eugene Wright, 153 Idaho 478

Wright was charged with armed robbery of a loan store and related conduct by two accomplices.
Circumstantial evidence linked Wright to the robbery, including descriptions, vehicle connection, shoe tread matches, and clothing and money evidence.
The State introduced evidence Wright refused to consent to photographing the soles of his shoes; Wright objected to relevance.
On the second trial day Wright discharged counsel and proceeded pro se; the court had previously ordered restraints after a marshal incident.
The district court restrained Wright during trial and informed the jury of the restraint; it is unclear if restraints continued throughout.
The jury found Wright guilty of robbery; Wright challenges restraint, prosecutorial misconduct regarding the shoe-soles issue, and other-acts evidence; the court vacates and remands for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether restraints were properly justified and prejudicial	Wright: restraint unsupported by record; improper to alert jury.	Wright: records show necessity and least-restrictive means not used.	Remand for new trial; restraints not adequately justified.
Prosecutorial misconduct from referencing Wright's refusal to consent to a search	Refusal to consent to search implicates Fourth Amendment rights and harmed trial.	Not a true Fourth Amendment search; references were permissible or not plain error.	No fundamental error; statements not shown to involve unwaived rights or plain error.
Admission of evidence of other acts to show plan or identity	Bank-area conduct and clothing tied Wright to crime and should be admissible.	Evidence irrelevant to the charged robbery and overly prejudicial.	Evidence deemed relevant to identify Wright and show preparation; no error found.

Deck v. Missouri, 544 U.S. 622 (U.S. 2005) (restrictions on visible restraints require justification; reversible if lacking)
Crawford v. United States, 99 Idaho 87 (Idaho Ct. App. 1978) (restraints must be justified; due process concerns)
Moen, 94 Idaho 477 (Idaho Ct. App. 1971) (record must justify restraints; preferred proceedings)
Knutson, 121 Idaho 101 (Ct. App. 1991) (on-record justification and visibility considerations for restraints)
Perry, 150 Idaho 209 (Idaho 2010) (Chapman harmless error standard adopted in Idaho)
Betancourt, 151 Idaho 635 (Ct. App. 2011) (fundamental error requires unwaived rights and plain error analysis)
State v. Johnson, 148 Idaho 664 (Ct. App. 2010) (Rule 404(b) applicability and relevance in other-acts context)