Foster v. California
Headline: Unfair police lineup procedures found to violate due process, so the Court reversed an armed-robbery conviction and sent the case back, limiting reliance on suggestive eyewitness identifications.
Holding: The Court held that the police arranged identification procedures so unnecessarily suggestive that they violated the defendant’s right to due process, reversed his armed-robbery conviction, and remanded for further proceedings.
- Stops convictions based on blatantly suggestive lineups.
- Requires courts to assess identification reliability case-by-case.
- Leaves harmless-error review to lower courts.
Summary
Background
A man was tried for an armed robbery of a Western Union office after an alleged accomplice surrendered and implicated him. The only eyewitness was the night manager, who first viewed a three-man lineup that included the tall defendant and two much shorter men. The witness was uncertain. He then met the defendant alone in an office and remained unsure. About a week later the police held a five-man lineup in which the defendant was the only repeat participant, and the witness then became convinced the defendant was the robber. At trial the witness again identified the defendant and the accomplice also testified for the prosecution; the defendant was convicted.
Reasoning
The Court focused on whether the way police arranged the identifications was so suggestive that it violated the defendant’s right to fair treatment under the Constitution. The Court explained that even though earlier cases about counsel at lineups did not apply to these pre-June 1967 lineups, courts must still judge identification procedures by the “totality of the circumstances.” Here the repeated one-on-one confrontation, the defendant’s obvious difference in height and clothing, and his sole repeat appearance made identification almost inevitable. The Court concluded those procedures so undermined reliability that they denied due process and reversed the conviction, while leaving the question of harmless error to the state courts.
Real world impact
The ruling requires courts to look closely at how police conduct lineups and prevents convictions based on identifications produced by clearly suggestive procedures. The case was sent back so lower courts can decide whether the error was harmless or requires further action.
Dissents or concurrances
A dissent argued the jury should weigh the witnesses’ testimony and criticized using a broad fairness test to exclude eyewitness evidence, warning about limits on jury factfinding.
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