Does a reference to her custodial status undermine the presumption of innocence?

We disagree with Wyly that the reference to her custodial status undermined the presumption of innocence, as in cases where defendants were forced to wear prison garb to trial. See Estelle v. Williams, 425 U.S. 501, 518 (1976). We do, however, find that admission of this evidence was improper. Whatever minimal relevance this statement had was easily outweighed by the considerable risk of unfair prejudice. But even where a district court abuses its discretion, reversal is

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