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Scales v. State

2025-08-26

Summary

Holding. The Supreme Court of Georgia denied the petition for certiorari.

Bernard Scales was charged with murder and other crimes. During trial, law enforcement attached a security device called a "Band-it" to his person without a prior hearing to establish specific reasons for this restraint. After his conviction, Scales moved for a new trial, claiming the device violated his constitutional rights to be present, participate in his defense, testify, and receive equal protection. The Court of Appeals upheld the trial court's denial of the motion, finding no demonstrated harm to his constitutional rights and ruling that any procedural error was harmless beyond a reasonable doubt.

The Georgia Supreme Court denied Scales's petition for certiorari. A concurring opinion emphasized the difficult balance trial judges must strike between courtroom security and defendant constitutional protections. The concurrence noted that the security device was applied pursuant to a standard operating procedure that allowed law enforcement supervisors discretion to use such measures on all incarcerated felony defendants without court-ordered individualized findings. The opinion cautioned that while courtroom security is important, trial courts retain ultimate responsibility for ensuring defendants' constitutional rights are protected and cannot delegate this authority entirely to law enforcement.

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

Key issues

  • Whether applying a security restraint device to a defendant without a pre-restraint hearing violates due process rights
  • Whether restriction of defendant's movement during trial violates constitutional rights to be present and participate in defense
  • Proper allocation of authority between trial courts and law enforcement in courtroom security decisions
  • Whether harmless error analysis applies to restraint-related constitutional violations

Procedural posture

The defendant appealed a trial court's denial of his motion for new trial following conviction, and the Court of Appeals affirmed; the defendant then petitioned the Georgia Supreme Court for certiorari.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

SUPREME COURT OF GEORGIA

Case No. S25C0749

August 26, 2025

The Honorable Supreme Court met pursuant to adjournment.

The following order was passed:

BERNARD SCALES v. THE STATE

The Supreme Court today denied the petition for certiorari in

this case.

All the Justices concur, except Land, J., disqualified.

Court of Appeals Case No. A24A1351

SUPREME COURT OF THE STATE OF GEORGIA

Clerk’s Office, Atlanta

I certify that the above is a true extract from the

minutes of the Supreme Court of Georgia.

Witness my signature and the seal of said court hereto

affixed the day and year last above written.

, Clerk

LAGRUA, Justice, concurring.

Trial court judges have a difficult job in many respects, but

particularly, when it involves balancing the constitutional rights of

a defendant and the presumption of innocence, while also ensuring

that litigants, witnesses, juries, and the public are safe and secure

in the courtroom. In an era of pervasive threats to judges and court

personnel, it has become increasingly challenging to balance those

two interests.

That said, judges take an oath to follow the law, and the law

mandates that we protect the rights of parties, including

defendants, in the courtroom and elsewhere, especially during trial.

That is why I join fully in the majority’s denial of certiorari, but

again caution trial judges that security within the courtroom is

under their control and cannot be abdicated to law enforcement

personnel. See Green v. State, 246 Ga. 598, 600 (1980).

Scales was charged with murder and other crimes. During

trial, the Sheriff’s Department attached a “Band-it” security device

to his person without a hearing laying out fact-specific reasons

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addressing the need for additional security measures. Scales was

ultimately convicted and sentenced. He then filed a motion for new

trial, alleging for the first time, that among other things, his due

process rights to be present, and meaningfully participate in his own

defense, his right to testify, his right to equal protection, and his

right against abuse of prisoners, had been violated because he was

required to wear the “Band-it” security device.

The Court of Appeals found that

[i]n denying the motion for new trial, the trial court found

that Scales failed to demonstrate any harm to his

constitutional right to testify and participate in his own

defense based on the use of the Band-it, and to the extent

the court erred in failing to hold a hearing prior to placing

the device on him, any such error was harmless beyond a

reasonable doubt because ample grounds existed to

authorize the use of the device.

Scales v. State, 374 Ga. App. 257, 258 (2025).

The specific facts of this case are addressed in the opinion of

the Court of Appeals. What concerns me is that the testimony at the

motion-for-new-trial hearing established, and the State does not

now dispute, that use of the “Band-it” security device is controlled

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by the Supervisor of Court Services (which in this case was Lt.

Richard Harrison with the Carroll County Sheriff’s Office) pursuant

to a written Standard Operating Procedure (“SOP”). The SOP gives

the supervisor the discretion to use additional security measures

deemed appropriate (adhering to certain guidelines) without the

court making specific findings addressing the need for additional

security. However, according to Lt. Harrison’s testimony at the

motion-for-new-trial hearing, the Band-it is used on every

incarcerated defendant brought to trial on a felony charge.

As I have consistently cautioned trial courts: “It is well

established that no person should be tried while shackled except as

a last resort,” Hill v. State, 308 Ga. 638, 644 (2020) (cleaned up), and

should a trial court utilize shackles the trial court must make “casespecific and individualized findings to support its initial decision.”

Id. That decision should clearly be made with input from the law

enforcement agency tasked with securing the courtroom, but the

ultimate decision remains with the court.

Webster’s dictionary defines shackling as “something that

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confines the legs or arms,” as well as “to deprive of freedom

especially of action by means of restrictions or handicaps.” Based on

the testimony at the motion for new trial, Lt. Harrison made clear

that the “Band-it,” once activated, would restrict the defendant’s

ability to move around.

Trial courts have a heavy burden to protect the people that

enter the courtroom they supervise, and while that is a trying

responsibility in these times and while it is understandable to want

to use restrictions to ensure a high level of safety and public

confidence in the security of the courtroom, ensuring a defendant’s

constitutional rights remains paramount. When we do not keep that

at the very forefront of our minds, we risk the rights of us all.

I am authorized to state that Justice McMillian joins in this

concurral.

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