Background
Moreion Lindsey was convicted by a jury of conspiracy to commit murder for hire and murder for hire. The district court sentenced him to two concurrent life sentences. Before trial, the government requested leg restraints due to safety concerns, citing Lindsey’s prior convictions for assault and firearm possession. Although the district court initially seemed to deny the motion, the marshals brought Lindsey into the courtroom in leg shackles on the first day of trial. The district court stated the decision was made by the marshals and noted a uniform courthouse approach, while also citing Lindsey’s history and the nature of the offense. Lindsey’s counsel did not request additional findings and stated he did not care about the restraints issue, though he confirmed a screen was in place to hide the restraints from the jury.
The court’s reasoning
The Eighth Circuit reviewed the district court’s security decisions for abuse of discretion. The court noted that the defendant was responsible for the record he challenged because his counsel did not object to the level of detail in the findings and stated he did not care about the issue. Even assuming the objection was preserved, the court found no abuse of discretion. The district court took steps to mitigate prejudice by using table skirts to obstruct the jury’s view, and there was no evidence the jury saw the restraints. The court concluded the district court adequately justified the restraints by citing Lindsey’s serious pending charges and violent criminal history. The court also rejected the argument that the Supreme Court’s decision in Deck v. Missouri applied, noting that Deck’s stricter standard applies only when restraints are visible to the jury or when there is no adequate justification. Here, the district court engaged in a particularized inquiry based on Lindsey’s specific history and charges.
In light of the limited risk of prejudice evident here and the seriousness of Lindsey’s charges and criminal history, we conclude the district court did not abuse its discretion in ordering Lindsey restrained.
United States v. Moreion Lindsey, 25-1956 (8th Cir. 2026)
What it means going forward
This decision reinforces that district courts have broad discretion to order restraints for defendants with violent histories, provided the restraints are concealed and the court cites specific security concerns. It clarifies that the heightened burden of proof under Deck v. Missouri does not apply to concealed restraints where adequate justification exists.