Illinois Appellate Court
Criminal Court
Use of Restraints
Defendant was found guilty of home invasion, residential burglary, and unlawful possession of a stolen vehicle. On appeal, he argued that plain error occurred when the trial court ordered defendant be placed in restraints during his cross-examination or, in the alternative, that counsel was ineffective for failing to object. The appellate court found that the trial court abused its discretion and that error occurred, but affirmed on the basis that the record did not support a finding that the outcome would have been different but for the error. (HAUPTMAN and HOLDRIDGE, concurring)