 Blackstone, a politician, judge and jurist, wrote “it is laid down in our ancient books, that, though under an indictment of the highest nature, a defendant must be brought to the bar without irons, or any manner of shackles or bonds; unless there be evident danger of an escape.” Next, the court looked at more recent opinions to show that this rule relates to a defendant's right to due process.The court looked at the dictum of three cases, "Illinois v. Allen", "Holbrook v. Flynn" and "Estelle v. Williams".In Allen, the Court said that trial courts should only use shackles on defendants, during the guilty phase, as a “last resort.” In Holbrook, the court stated that shackling is “prejudicial” and should only be allowed when state interests are involved.