Can a criminal defendant be physically restrained in the presence of the jury?

A criminal defendant cannot be physically restrained in the jury's presence unless there is a showing of manifest need for such restraints. (People v. Duran (1976) 16 Cal.3d 282, 290-291, 127 Cal.Rptr. 618, 545 P.2d 1322 (Duran)). Such a showing, which must appear as a matter of record (id., at p. 291, 127 Cal. Rptr. 618, 545 P.2d 1322), may be satisfied by evidence, for example, that the defendant plans to engage in violent or disruptive behavior in court, or that he plans to escape from the courtroom (id., at pp. 292-293, fn. 11, 127 Cal.Rptr. 618, 545 P.2d 1322). A shackling decision must be based on facts, not mere rumor or innuendo. (Cox, supra, 53 Cal.3d 618, 651-652, 280 Cal.Rptr. 692, 809 P.2d 351.)