The Restraint Chair

The restraint chair is a carceral technology that allows state actors to completely immobilize a person by binding each of their limbs and their chest to a special chair. The use of restraint chairs has quietly proliferated in jails and prisons over the past thirty years. State actors now use them to force people into total restraint tens of thousands of times per year. Jailers justify buying these chairs as a technology of last resort, for use only in moments of imminent danger. But in practice state actors routinely deploy the technology for punishment and for convenience. Jailers hold people in total restraint for dozens of hours, often denying the restrained people water and access to a restroom. State actors frequently combine restraint with isolation and "spit guards," which are mesh bags forced over people's heads. The result is people strapped to chairs, alone, in concrete cells, with bags over their heads, being forced to sit in their own feces and urine. Despite the routine and extreme nature of this practice, restraint chairs exist in a near-complete legal void. There is vanishingly little legal interpretation of the technology and no scholarship directly addressing it. Their acquisition and use are rarely governed by statute or regulation, and judicial review is exceedingly rare. This silence is particularly striking because robust legal interpretation is often theorized as a necessary precursor to state violence. This Article addresses the immense gap between the hidden violence of this carceral technology and the absence of legal interpretation surrounding it. I argue that the violence of the restraint chair persists despite the lack of legal interpretation because it sits at the confluence of four historical channels of dehumanization-the restraint of the insane, the shackling of slaves, the torture of enemies of the state, and the caging of prisoners. This analysis leads to the Article's broader theoretical contribution: legal silence is itself a mechanism through which technologies of state violence proliferate, as this silence allows them to spread along existing channels of dehumanization. By surfacing the restraint chair as a case study in interpretive silence, the Article offers a framework for understanding how unregulated carceral technologies emerge and persist-and shows why bringing them into legal view is a necessary first step toward limiting their harms.