TIFFANY A. v. Superior Court

59 Cal. Rptr. 3d 363, 150 Cal. App. 4th 1344, 2007 Cal. Daily Op. Serv. 5600, 2007 Cal. App. LEXIS 783
CourtCalifornia Court of Appeal
DecidedMay 21, 2007
DocketB193134
StatusPublished
Cited by14 cases

This text of 59 Cal. Rptr. 3d 363 (TIFFANY A. v. Superior Court) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TIFFANY A. v. Superior Court, 59 Cal. Rptr. 3d 363, 150 Cal. App. 4th 1344, 2007 Cal. Daily Op. Serv. 5600, 2007 Cal. App. LEXIS 783 (Cal. Ct. App. 2007).

Opinion

Opinion

WOODS, J.

Tiffany A. seeks a writ of prohibition directing the lower court to set aside its order denying her motion to preclude the use of physical restraints upon all minors who appear in juvenile court proceedings in the Lancaster Juvenile Delinquency Court absent an individualized determination of need for the restraints. Petitioner complains the juvenile delinquency court’s general policy requiring all minors to be shackled is contrary to the established law concerning the appropriate use of physical restraints during court proceedings. The real party in interest, the People, and amicus curiae, the Los Angeles County Sheriff’s Department, assert, inter alia, the requisite showing of need for the use of restraints depends on the type of court proceeding. They claim that where the proceedings are before a judge rather than a jury, do not involve witnesses, and are brief and/or uncontested, the necessary showing of need is far less, and does not have to be particularized as to the individual. Thus, as respondent court did in denying the motion below, they defend the general policy arguing the use of restraints in the Lancaster courtroom for all minors is warranted based on safety concerns arising from the design of the courthouse facility as well as the lack of sufficient numbers of security personnel available to monitor the courtroom. Finally, they defend the use of the policy claiming that the case law limiting the use of restraints in the courtroom arises only in the context of criminal proceedings involving adults, and thus this case law should not be applied in the context of juvenile delinquency proceedings. As we shall explain, the court’s reasons for denying petitioner’s motion, and the real party in interest and the sheriff’s department’s reasons for defending the policy, are without merit. In our view, the use of physical restraints upon minors who appear in the Lancaster Juvenile Delinquency Court must be based on a showing that such restraints are necessary for each individual minor irrespective of the type of hearing or proceeding. Consequently, we issue the writ of prohibition.

FACTUAL AND PROCEDURAL BACKGROUND

The Policy for the Use of Ankle Restraints on Minors

Juvenile delinquency matters are heard in department 285 in the Alfred J. McCourtney Juvenile Justice Center in Lancaster, California. Though a total *1349 of six sheriff’s deputies are assigned to the courthouse, only one deputy-is assigned as a bailiff in department 285. 1 Department 285 has four exit doors from the courtroom and a number of those doors lead to unsecured exits, public areas and/or to outside the building.

The juvenile court in department 285 has a practice and policy to put ankle shackles on all detained minors who appear in the courtroom for all proceedings. This policy has been in place for at least two years. 2 3The policy of shackling minors while in the courtroom was adopted because of the number of unlocked exits and unsecured hallways in the courtroom and because of the lack of sheriff’s personnel available to monitor the facility. According to the sheriff’s sergeant in charge of the security and custody at the courthouse, the risk of minors escaping the courtroom is significant given the design of the courtroom and location of the courthouse. The sheriff’s sergeant opined the use of shackles on all minors has prevented escape attempts and allowed order to be maintained in the courthouse. The sheriff s sergeant concluded the use of ankle restraints upon minors “is like having another deputy present .... Just as having a deputy at the minor’s side causes him or her to think twice about any attempt to escape or to cause trouble, so too do ankle restraints, which every minor immediately realizes eliminates any possibility of making a serious escape attempt. If we had a different facility—with locked doors, secured hallways and courtrooms, sally ports, etc.—it might be possible to maintain security without the use of the ankle restraints. But ih this facility, ankle restraints are the simplest, least intrusive [3] method of maintaining security.”

The Case of Tiffany A.

Petitioner became the subject of a wardship petition brought under Welfare and Institutions Code section 602. The petition alleged 16-year-old Tiffany A. committed the crime of unlawful taking of a vehicle (i.e., a car belonging to *1350 her mother) in violation of Vehicle Code section 10851, subdivision (a). On June 1, 2006, at an uncontested predisposition hearing, Tiffany A. objected to the fact that she was shackled with leg chains during the proceedings..

Her counsel stated: “Your honor, Tiffany is shackled with leg chains because she is in custody. We would object to her being shackled because of the fact that the court cannot use restraints without showing a manifest need, we’re citing People v. Frier [Vc] (1991) 1 Cal.4th 173 [3 Cal.Rptr.2d 426, 821 P.2d 1302]. So at this point we would ask the court to remove the shackles.”

The Court: “Okay. Your request is denied. The case you are citing does not apply to juveniles. . . . The main reason the minors that are in custody are shackled is because we do not have a secure egress and ingress to this courtroom like we did in the old building. But your objection is noted and overruled. ...”

Thereafter on June 16, 2006, petitioner filed a motion to prohibit the use of shackles upon minors in the courtroom; 4 asking the court to make an ordpr prohibiting the sheriff from using such physical restraints, unless the shackling had been ordered by the court based on an individualized evidentiary showing of “manifest need.” Petitioner’s counsel also attached her declaration stating that all of her clients are brought into the courtroom in leg shackles for all court appearances. She also stated she had been told the reason for the use of the restraints related to the inadequate security in the building housing the courthouse.

At the June 19, 2006, hearing on the motion, the court ruled as follows: *1351 They have even gone—some of these cases, they indicate that the defendant can’t be shackled at arraignment or any post pre-trial hearing unless there is a showing that they need to be. And again, however, though nothing to address Juveniles.

*1350 “[A]s I said before on this subject, there are no cases in California law dealing with minors on this issue.
“From what I am-reading, that a lot'of these cases started out dealing with the defendant being handcuffed, shackled in the presence of the jury. And that was ruled by the court, you can’t do that, understandably so, you don’t want the jury to be prejudiced. There is no jury in Juvenile. The court is the jury.
*1351

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Bluebook (online)
59 Cal. Rptr. 3d 363, 150 Cal. App. 4th 1344, 2007 Cal. Daily Op. Serv. 5600, 2007 Cal. App. LEXIS 783, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tiffany-a-v-superior-court-calctapp-2007.