People v. Roman, 34 N.Y.2d 777, 357 N.Y.S.2d 978 (1974)

A defendant in a criminal trial is presumed innocent and has the right to appear in court in civilian clothing, ensuring they are not visually identified as a convict to the jury.

Summary

The defendant, Roman, was denied his request to wear civilian clothing during his trial and was compelled to appear in prison attire. The Court of Appeals reversed the lower court’s decision, holding that forcing a defendant to wear prison clothing violates their right to be presumed innocent. The court reasoned that requiring a defendant to appear in convict’s attire serves as a constant visual reminder to the jury of their incarcerated status, undermining the principle that they are entitled to the dignity and self-respect of a free and innocent person.

Facts

The defendant, Roman, was on trial. Prior to the commencement of the trial, Roman’s counsel requested that he be allowed to wear his own street clothes during the proceedings. The trial court denied this request, compelling Roman to appear in “distinctive prison attire.”. The prosecution could not provide a reason for this requirement.

Procedural History

The trial court denied the defendant’s request to wear civilian clothing. The Appellate Term affirmed the trial court’s decision. The New York Court of Appeals then reviewed the case.

Issue(s)

Whether a defendant’s right to a fair trial is violated when they are compelled to appear before a jury in prison attire, thereby undermining the presumption of innocence.

Holding

Yes, because compelling a defendant to wear prison attire during trial undermines the presumption of innocence and denies them the right to appear in court with the dignity and self-respect of a free person.

Court’s Reasoning

The court emphasized the fundamental principle that a defendant is presumed innocent and is entitled to appear in court with the dignity and self-respect of a free and innocent person. Requiring a defendant to wear prison attire acts as a continuous visual communication to the jury that the defendant is an incarcerated individual, thereby undermining the presumption of innocence. The court stated, “To forbid him to wear his own clothing and to require him to appear in convict’s attire — a continuing visual communication to the jury — is to deny him this right.” The court acknowledged that there might be situations where accommodating a defendant’s request to wear civilian clothing presents practical challenges, but no such challenges were present in this case. The fact that the defendant’s alleged crimes were committed while incarcerated was deemed irrelevant to the issue of whether he should be allowed to wear civilian clothing during the trial. The court explicitly rejected the reasoning in United States ex rel. Stahl v. Henderson, which suggested a different outcome when the alleged crimes occurred during incarceration.