State of Washington v. Luthi

Held that an in-court holding cell, even during pretrial hearings when a jury is not present, undermines the presumption of innocence, limits defendants’ ability to confer confidentially with counsel, and is contrary to the “formal dignity” of the courtroom and treating defendants’ respectfully. To satisfy due process, a trial court must engage in an inquiry before every hearing to determine if there are extraordinary circumstances justifying courtroom restraints.