California, United States of America
The following excerpt is from People v. Castellano, F066005 (Cal. App. 2015):
" 'Manifest need' arises only upon a showing of unruliness, an announced intention to escape, or '[e]vidence of any nonconforming conduct or planned nonconforming conduct which disrupts or would disrupt the judicial process if unrestrained ....' [Citation.] Moreover, '[t]he showing of nonconforming behavior ... must appear as a matter of record ....' [Citation.]" (People v. Cox (1991) 53 Cal.3d 618, 651, disapproved on other grounds in People v. Doolin (2009) 45 Cal.4th 390, 421, fn. 22.)
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