1 U.S. at 128 & n.3; accord
Sanchez-Berrios, 424 F.3d at 76; Eaglin, 571 F.2d at 1078.
   13
      At oral argument, counsel for Laverdure argued that the constitutional
error stemmed from the combined effect of the seating arrangement and
the proximity of federal marshals. The complaint about the marshals’ pres-
ence, however, was raised for the first time at oral argument. It was not
argued in the briefs, nor was there even any mention of it in the trial
record. We consider it waived. See Arpin v. Santa Clara Valley Transp.
Agency, 261 F.3d 912, 919 (9th Cir. 2001) (“[I]ssues which are not specif-
ically and distinctly argued and raised in a party’s opening brief are
waived.”).
10288              UNITED STATES v. LARSON
when the practice creates “an unacceptable risk . . . of imper-
missible factors coming into play.” Williams, 425 U.S. at 505.

                               1

   The courts have invalidated various courtroom arrange-
ments and procedures as violating the right to a fair trial. See
Deck, 544 U.S. at 632-35 (invalidating the routine practice of
compelling defendants during the punishment phase of capital
cases to wear visible shackles); Williams, 425 U.S. at 503-05
(invalidating the trial court’s requirement that a defendant
appear in prison garb); Musladin v. LaMarque, 427 F.3d 653,
656-60 (9th Cir. 2005) (reversing a murder conviction
because spectators wore buttons depicting the alleged victim’s
photograph), cert. granted sub nom. Carey v. Musladin, 126
S. Ct. 1769 (2006); United States v. Olvera, 30 F.3d 1195,
1198 (9th Cir. 1994) (reversing a conviction because the
defendant was compelled to speak the words of the bank rob-
ber in front of the jury); Norris v. Risley, 918 F.2d 828, 831-
34 (9th Cir. 1990) (reversing a rape conviction because spec-
tators wore anti-rape buttons).

   In contrast, the Supreme Court has upheld an arrangement
by which four uniformed security personnel sat in the first
row of the courtroom’s spectator section. See Holbrook v.
Flynn, 475 U.S. 