Does a court have to compel a defendant to wear a stun belt at trial?

On the contrary, the trial court's comments suggest that its rejection of defendant's objection to the use of the stun belt was based at least in significant part upon the court's determination that the use of the belt would be in defendant's best interest because the belt would help defendant control his emotions and not act in a manner that would be detrimental to his case, rather than being premised upon a judicial conclusion that defendant posed a sufficient danger of violent conduct in the courtroom to demonstrate a manifest need for the use of a restraint under Duran. Although the trial court undoubtedly had defendant's best interests at heart, even if the use of such a device objectively were in the defendant's best interests the trial court could not compel defendant to wear such a device over objection without the showing and determination required by Duran. (Accord, Faretta v. California (1975) 422 U.S. 806, 834-835, 95 S.Ct. 2525, 45 L.Ed.2d 562 [a court may not compel a competent defendant to be represented at trial by counsel rather than to represent himself or herself, even if the court reasonably believes that representation by counsel is in the defendant's best interest].) In this case, the record does not establish that the trial court's decision to compel the use of a stun belt was based upon its determination that there was a manifest need to impose such a restraint for security purposes. In the absence of such a showing and finding, under the principles of Duran the trial court could not properly compel defendant to bear the burden of testifying while subjected to a remote-controlled stun belt that defendant objected to wearing. Accordingly, we conclude that the trial court abused its discretion in rejecting defendant's objection to the use of a stun belt.⁶