United States v. Crews

1980-03-25

Headline: Court allows victims’ in-court identifications even after an unlawful arrest, holding courtroom eyewitness testimony admissible when the victim’s memory and police knowledge existed before the illegal detention.

Holding: The Court held that a victim’s in-court identification need not be suppressed as the product of an unlawful arrest when the witness’s memory and the police’s information about the suspect existed before the illegal detention.

Real World Impact:

Allows prosecutors to use victims’ courtroom identifications when witnesses’ memories predate illegal police detention.
Pretrial photo and lineup IDs obtained after an unlawful arrest remain suppressible.
An illegal arrest alone does not prevent later prosecution or courtroom identification.

Topics: eyewitness identification, police arrest practices, criminal procedure, evidence admissibility

Summary

Background

A young man was accused of a series of robberies and assaults in a women’s restroom at a national monument. After the first victim reported the attack, police received matching descriptions from other victims. Officers detained the suspect briefly as a suspected truant on January 9, photographed him, and released him; the next day a victim picked his photo from an array and later identified him at a lineup and in court. The trial court found the January 9 detention lacked probable cause and suppressed the pretrial photo and lineup identifications; the Court of Appeals then ordered suppression of the victim’s in-court identification as well.

Reasoning

The Supreme Court considered whether a courtroom identification must be excluded as the “fruit” of the earlier illegal detention. The Court explained that an in-court identification has three parts: the witness’s presence at trial, her ability to recall the crime, and the defendant’s presence in the courtroom. The opinion held that none of those elements resulted from the unlawful detention here. The victim had given descriptions and formed a memory of her assailant before the detention, and the police already had reason to suspect the defendant. The Court therefore ruled the in-court identification admissible, even though the pretrial photo and lineup taken after the illegal detention were suppressible.

Real world impact

The decision lets prosecutors use eyewitness testimony at trial when victims’ memories and police information predate any illegal arrest, while still excluding pretrial IDs obtained from unlawful detentions. The ruling does not excuse illegal arrests, but it limits the exclusionary rule’s reach in such circumstances.

Dissents or concurrances

Several Justices joined the result but wrote separately. One concurrence would explicitly state that a defendant’s face cannot be treated as suppressible evidence; another emphasized existing cases that allow trials despite earlier illegal arrests.