Ricky Cuong Hoang v. the People of the State of Colorado

Summary

The court affirmed the court of appeals’ judgment on both shackling and appellate-delay issues. It held that the heightened constitutional harmless-error standard for shackling applies only when the restraints were visible to jurors or the record supports a reasonable inference that a juror saw or heard them; Hoang did not meet that threshold. The court also held that an incomplete record requires a showing of specific prejudice and that appellate delay is evaluated under an adapted four-factor framework focused on whether the delay impaired the appeal or a possible retrial. No separate opinions were filed.