Illinois v. Allen

Allen (defendant) repeatedly disrupted his own criminal trial with antagonistic behavior despite the judge's warnings, prompting the judge to order his removal so the trial could proceed without him, though Allen was later allowed to return and was removed again when the disruptive behavior resumed; he was ultimately permitted to return for the remainder of trial after promising to behave. After conviction, the court of appeals held a defendant can never be denied the right to be present at his own trial, and the Supreme Court granted certiorari.