People v. Rippatoe 

Defendant was convicted, after jury trial, of home invasion and resisting or obstructing a peace officer. Court erred in failing to conduct inquiry into need for Defendant to be shackled during his pro se presentment of his posttrial motion. As Defendant questioned witnesses and gave testimony while shackled, even having great difficulty raising his hand to take oath, shackling was unfair and demeaning to integrity of proceedings. Although it was clear error for judge to rely on his personal knowledge of defense counsel in assessing ineffective assistance of counsel claim, counsel's decision not to call witness was matter of trial strategy, and Defendant did not show prejudice. (CARTER and O'BRIEN, concurring.)