Rhonda Jean Dyas v. Susan Poole, Warden Attorney General of the State of California

The State of California appeals a conditional grant of a writ of habeas corpus. The district court held that petitioner Rhonda Jean Dyas had been unconstitutionally shackled during her trial and that the shackling prejudiced her. The State does not dispute that the shackling was unconstitutional; it challenges only the holding that Dyas was prejudiced.

Dyas was convicted in California state court of first degree murder and robbery in 1991. The murder was carried out by Dyas’s husband and another man. Dyas prevented another person, Tina Boyd, from going into the room during the murder and may have been otherwise involved. Testimony at trial was contradictory and the jury took 3 days to deliberate following Dyas’s 5-day trial.

During trial, Dyas was kept in leg shackles in the courtroom. Her attorney had asked that she not be shackled in the courtroom. The trial judge denied the request, stating only that he did not believe the shackles would be “so visible that they come to the attention of the jury at all unless it’s brought to their attention” and that the nature of the case was such that he preferred the defendants to wear leg restraints. Dyas was also shackled while…