Okla. Stat. » Title 22 — CRIMINAL PROCEDURE
Oklahoma Statutes

Okla. Stat. tit. 22, § 15 (2026)

Testimony against one's self - Restraint during trial and

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prior to conviction. No person can be compelled in a criminal action to be witness against himself; nor can a person charged with a public offense be subjected before conviction to any more restraint than is necessary for his detention to answer the charge, and in no event shall he be tried before a jury while in chains or shackles. R.L.1910, § 5549; Laws 1953, p. 97, § 1.

Notes of Decisions
Cited in 25 cases, 1966–2018 · leading case: Mitchell v. State, 2016 OK CR 21, 387 P.3d 934.
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Mitchell v. State, 2016 OK CR 21, 387 P.3d 934. · cites it 2× “Before ordering a defendant to be restrained, a trial court must specifically find, on the record, that he "has engaged in disruptive or aggressive behavior in connection with the proceedings, or made an express or implied threat to disrupt the proceedings or endanger public…”
Bramlett v. State, 2018 OK CR 19, 422 P.3d 788. · cites it 2× “2011, § 15 provides: No person can be compelled in a criminal action to be witness against himself; nor can a person charged with a public offense be subjected before conviction to any more restraint than is necessary for his detention to answer the charge, and in no event shall…”
Duclos v. State, 2017 OK CR 8, 400 P.3d 781. · cites it 2× “2d 1017, 1033-34 , this Court found that a violation of the prohibition against trial in physical restraints set forth in 22 O.S.1991, § 15 constituted harmless error in the absence of any prejudice.”
Grant v. State, 2002 OK CR 36, 58 P.3d 783. · cites it 4× “At trial, Grant objected to this treatment, arguing that it was tantamount to placing him in handcuffs or shackles and made him look like an animal.”
Phillips v. State, 1999 OK CR 38, 989 P.2d 1017. · cites it 2× “See also 22 O.S.1991, § 15. This Court noted the policy behind such a rule stating in part that a criminal defendant was entitled to appear in court with free use of his faculties, both mentally and physically citing French v.”
Ochoa v. State, 2006 OK CR 21, 136 P.3d 661. · cites it 3× “2d 207 , when addressing a claim that the defendant was improperly tried in leg shackles in both stages of a capital murder trial, we held the procedure violated 22 O.S. § 15 and, in the absence of waiver, the trial court had no discretion in the matter, and the defendant should…”
Burks v. State, 594 P.2d 771 (Okla. Crim. App. 1979). “II, § 21, of the Oklahoma Constitution, as further codified in 22 O.S.1971, § 15, that no person be compelled in a criminal action to be a witness against himself.”
Roberts v. State, 571 P.2d 129 (Okla. Crim. App. 1977). · cites it 2× “The defendant argues that the trial court violated 22 O.S.1971, § 15, which provides: “No person can be compelled in a criminal action to be witness against himself; nor can a person charged with a public offense be subjected before conviction to any more restraint than is…”
Davis v. State, 709 P.2d 207 (Okla. Crim. App. 1985). · cites it 2× “Appellant alleges this procedure was in violation of 22 O.S.1981, § 15, and we agree. Title 22 O.”
Robedeaux v. State, 866 P.2d 417 (Okla. Crim. App. 1993). “Appellant alleges several persons on the jury panel saw him in handcuffs in the doorway of the jail elevator, thus *424 violating 22 O.S.1981, § 15, which requires in part that no defendant be tried before a jury in chain or shackles.”
French v. State, 416 P.2d 171 (Okla. Crim. App. 1966). · cites it 3× “He argues that the jurors probably saw the film and assuming that they saw the defendant filmed in chains amounted to a violation of 22 O.S. § 15, the same providing: "No person can be compelled in a criminal action to be witness against himself; nor can a person charged with a…”
Mehdipour v. State, 1998 OK CR 23, 956 P.2d 911. · cites it 2× “[12] 22 O.S.1991, § 15. [13] Robedeaux v. State, 866 P.”
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