The following excerpt is from United States v. Hart, 18-1593 (L), 18-1731 (C), 18-1783 (C), 18-1925 (C) (2nd Cir. 2021):
Hart argues that the district court should not have resorted to the leg restraints without first trying other methods, including a warning that a defendant would be held in contempt, or finding that other methods would be futile. But neither Illinois v. Allen, 397 U.S. 337 (1970), nor any other authority cited by Hart requires a district judge to try other methods first or to use the words "necessary as a last resort" when stating on the record that leg shackles are necessary.
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.