What happened
Allan Marshall, 30, from South Lanarkshire, was on remand at HMP Edinburgh for unpaid fines and breach of the peace. In March 2015 he was being moved to the segregation unit and taken to the shower room.
Footage released in 2026 shows him leaving his cell at 07:25 with three officers. He walked topless and calm for four minutes, at times held only by a light “come along hold” at the wrist, and entered the shower room at 07:29. There were no cameras in the shower room. Officers went in at 07:48 and the restraint began.
He was held face down by up to 17 officers at different times, some using their feet. He suffered a cardiac arrest during the restraint. Five officers were injured and needed hospital treatment.
He died four days later at Edinburgh Royal Infirmary.
The outcome
There were no criminal proceedings, so a fatal accident inquiry was mandatory. It began in November 2018, heard 25 days of evidence, and Sheriff Liddle published his determination on 9 August 2019.
The cause of death was a brain injury due to cardiac arrest during physical restraint, with underlying severe coronary artery disease. The determination found defects in the system that contributed and made 13 recommendations, including on control and restraint training and on recognising conditions that restraint can trigger.
Every officer involved was granted lifetime immunity from prosecution to secure their evidence, which the Crown Office later accepted was a mistake.
A civil claim under Article 2 by his family was live in 2026; Police Scotland and the Crown Office had agreed to pay compensation.
What went wrong
Two failures carried the determination. The first was medical: staff did not recognise the coronary disease that made a restraint potentially fatal, and the number of officers on a person is itself part of the clinical picture.
The second was supervisory. This was a prolonged restraint involving up to 17 officers at different times, and nobody’s task was to stand back and ask how long it had been running.
The inquiry also exposed how the account was built. The footage shows a calm man being walked to a shower room, which does not match the evidence officers gave of erratic and aggressive behaviour and a dirty protest.
What it teaches
Restraint is a medical event. A man with severe coronary disease can arrest under a hold that looks controlled, and the officer holding an arm is best placed to notice when the person underneath stops talking or changes colour.
Duration needs an owner. Where officers rotate, nobody holds the total, so someone’s only job has to be recording it.
Questions for the room
- He walked to the shower room calmly, in a hold a trainer would recognise. What made the restraint that followed necessary?
- You are the officer at the shower room door. What are you watching for, and how would you say out loud that something has changed?
- Seventeen officers at different times. Who was in charge of the duration?
Evidence and limits
Confidence: confirmed. The Scottish Government’s letter to the Justice Committee and BBC reporting were read, and they agree on the cause of death. The inquiry’s determination was not opened; its detail rests on those two sources.
The date is unsettled and the two working documents disagree. The record places the incident on 28 March 2015 and the death four days later; the précis dates the death itself to the same day. This page prints neither date and says four days, which is what the BBC reports.
The fatal accident inquiry concluded on 9 August 2019. No officer is named and none was prosecuted.
Our restraint reduction training covers how a service supervises a long restraint, not only how it starts one.
Sources
Reviewed 20 October 2026.