## Facts

- Harry Lee Williams, detained pretrial in Harris County, Texas because he could not post bond, was charged with assault with intent to commit murder with malice after a knife attack on his former landlord.
- On the morning of trial, Williams asked a jail officer for civilian clothes; none were provided.
- Williams was tried before a jury in identifiable jail clothing.
- During voir dire, defense counsel drew attention to Williams’s jail attire.
- Neither Williams nor his counsel asked the trial judge to permit civilian clothing or otherwise objected to the jail clothing at any time before or during trial.
- Evidence suggested many nonbailed defendants in the county were tried in jail clothes, but the record did not show this occurred when a timely objection was made; the trial judge’s practice was to allow civilian dress upon request.
- Williams was convicted and later claimed the jail clothing undermined the presumption of innocence in violation of the Fourteenth Amendment.

## Issues

1. Whether the Fourteenth Amendment is violated when a defendant is tried before a jury in identifiable prison clothing.
2. Whether the absence of a timely objection or request for civilian clothing defeats the required showing that the defendant was compelled to wear prison attire.

## Decision

- The Supreme Court reversed the Fifth Circuit and left the conviction in place.
- The Court held the State may not, consistent with due process, compel an accused to stand trial before a jury in identifiable prison clothes.
- The Court further held that when the defendant fails to object to being tried in prison clothing, the record ordinarily does not establish the compulsion necessary for a constitutional violation.
- Because Williams and counsel made no request to the trial judge and no objection, Williams did not show he was compelled to appear in jail clothing.

## Legal Principles

- Compelling a defendant to appear before a jury in identifiable prison clothing threatens the presumption of innocence and violates due process.
- The constitutional claim requires a showing of compulsion; a defendant’s failure to make a timely objection generally negates compulsion.
- The right not to be tried in prison attire may be waived, including by inaction, absent circumstances demonstrating compulsion.

## Conclusion

The Court recognized that forced trial in identifiable prison clothing violates due process, but held that Williams’s failure to object or seek relief from the trial judge meant he did not establish compulsion; accordingly, no Fourteenth Amendment violation was shown and the conviction stood.


Estelle v. Williams, 425 U.S. 501 (1976)