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  Trial Court Must Make Fact Findings Before Ordering Stun Belt
  
  
  
    
      
    
    
      
        The application of a stun belt to a criminal defendant is governed by the same considerations and body of law as restraint devices.  Such a decision "must be subjected to close judicial scrutiny to determine if there was an essential state interest furthered by compelling a defendant to wear shackles ...
    
  
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