UNITED STATES of America ex rel. Alfred STAHL, Petitioner-Appellant, v. C. Murray HENDERSON, Warden, Louisiana State Penitentiary, Respondent-Appellee

United States Court of Appeals for the Fifth Circuit1973-01-11No. No. 72-3013

472 F.2d 556

Summary · law.co

Holding. The court affirmed the district court's denial of habeas corpus relief, finding that the use of restraints during trial was justified by security concerns, that trying Stahl in prison uniform caused no prejudice where his inmate status was already known, and that the trial record showed effective assistance of counsel.

Alfred Stahl, an inmate convicted of murdering a fellow prisoner at Angola Prison, sought federal habeas relief challenging his 1958 conviction and life sentence. He raised three grounds for relief: that he was forced to stand trial while restrained in handcuffs, shackles, and a restraining belt with armed guards present; that he was tried while wearing a prison uniform bearing his number and nickname; and that he received ineffective assistance of counsel. The state trial court and state supreme court had previously denied his habeas petition, and the district court affirmed that denial on federal review.

The appellate court found no constitutional violation in any of Stahl's claims. Regarding the physical restraints, the court determined that the trial judge did not abuse discretion in imposing security measures based on Stahl's potential dangerousness. As for the prison uniform, the court reasoned that since the jury already knew Stahl was an inmate—both when the crime occurred and at trial—no prejudice resulted from seeing him in prison attire. The court distinguished Stahl's case from precedent requiring that a defendant affirmatively request civilian clothes before claiming prejudice from being tried in jail garb. Finally, the state trial record demonstrated that Stahl's three appointed counsel provided vigorous and able representation, defeating his ineffective assistance claim.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether courtroom restraints and security measures violate due process when justified by defendant's dangerousness
Whether trying a defendant in prison uniform prejudices him when his inmate status is already known to the jury
Whether allegations of ineffective counsel are supported by evidence of vigorous defense in the trial record

Procedural posture

Stahl appealed from the federal district court's denial of his habeas corpus petition, which had affirmed the state courts' prior denials of relief.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

majority opinion

PER CURIAM:

Alfred Stahl, a prisoner of the State of Louisiana, has appealed from the district court’s denial of his habeas corpus petition. We affirm.

Stahl, represented by three court-appointed counsel, was convicted upon trial by jury of murdering a fellow inmate at Angola Prison. He received a life sentence on February 28, 1958, the jury having returned a verdict of guilty without capital punishment. On direct appeal the judgment was affirmed. State v. Stahl, 1959, 236 La. 362, 107 So.2d 670.

Stahl was denied habeas relief by the Twentieth Judicial District Court of West Feliciana Parish, after an eviden-tiary hearing. Similar relief was denied by the Louisiana Supreme Court. State ex rel. Stahl v. Henderson, 1971, 260 La. 130, 255 So.2d 354.

In his federal habeas petition, Stahl contends that he is entitled to relief on grounds of (1) being forced to trial in handcuffs, shackles, and a restraining belt, with armed guards in the courtroom; (2) being put to trial wearing his striped prison uniform which bore his number and prison nickname; and (3) being represented by ineffective counsel.

The state trial court, after an evidentiary hearing, and the district court, on review of the state transcript, held that the security measures taken with regard to Stahl were justified by his potential dangerousness. We agree. The record clearly refutes Stahl’s argument that there was an abuse of discretion by the trial judge in permitting the use of restraining devices. See United States v. Bankston, 5 Cir. 1970, 424 F.2d 714; McCoy v. Wainwright, 5 Cir. 1968, 396 F.2d 818; Gregory v. United States, 8 Cir. 1966, 365 F.2d 203, cert. denied, 1967, 385 U.S. 1029, 87 S.Ct. 759, 17 L.Ed.2d 676; Odell v. Hudspeth, 10 Cir. 1951, 189 F.2d 300.

Stahl’s complaint of being tried in prison garb, if indeed he was, gives us little pause. He was on trial for the murder of a fellow inmate in the Louisiana State Prison where prison garb was Stahl’s normal attire. The jury necessarily knew that he was a prison inmate both at the time that he was alleged to have committed the crime and at the time of his trial. No prejudice can result from seeing that which is already known. Stahl’s reliance on Hernandez v. Beto, 5 Cir. 1971, 443 F.2d 634, cert. denied, 404 U.S. 897, 92 S.Ct. 201, 30 L.Ed.2d 174, is misplaced. There, the defendant, unable to make bond, was incarcerated while awaiting trial. He was subsequently tried in prison garb. We held that the defendant and his attorney had the burden to make known that the defendant desired to be tried in civilian clothes before the state could be accountable for his being tried in jail clothes, and that in the factual context of that case he had met his burden. Thus the trial in prison garb obviously impinged upon his presumption of innocence.

In Dennis v. Dees, E.D.La.1968, 278 F.Supp. 354, also relied on by Stahl, the district court primarily found an abuse of discretion by the trial judge in permitting an unusual and unnecessary show of force in the courtroom. Insofar as its holding may be in conflict with what we have said sub judice it is disapproved.

Stahl makes a conelusionary allegation in his petition .that his counsel was ineffective. There is an affirmative showing made in the state trial record supporting the district court’s finding that Stahl’s counsel were able and defended him vigorously. The judgment is

Affirmed.