Opinion · Supreme Court of the United States
Foster v. California
22 L. Ed. 2d 402
- Type
- Opinion
- Court
- Supreme Court of the United States
- Jurisdiction
- Federal
- Date
- 1969-04-01
- Topic
- general
holding that due process required the exclusion of an eyewitness identification obtained through police-arranged procedures that “made it all but inevitable that [the witness] would identify” defendant as the perpetrator. | noting that “in some cases the procedures leading to an eyewitness identification may be so defective as to make the identification constitutionally inadmissible as a matter of law” | holding that series of identification procedures, including a three-person, lineup where the defendant “stood out” due to his height and leather jacket, a subsequent “one-to-one confrontation” between the witness and the defendant, and a third lineup, was impermissibly suggestive | holding procedure impermissibly suggestive when in an initial lineup included considerably shorter men than defendant, and victim identified defendant only after a prior one-man viewing | explaining that cross-examination is the “time-honored process” for testing the reliability of the identifying witness and his or her identification of the suspect | stating that identification of a truck isn’t “governed by the constitutional limitations that control the identification of a defendant” | finding that due process required the exclusion of an eyewitness identification obtained through a procedure making identification of the defendant inevitable | finding that due process required the exclusion of an eyewitness identification obtained through a procedure making identification of the defendant inevitable | observing that the identification was “all but inevitable” under the circumstances | finding photo of suspect unduly suggestive because of his height and that “he was wearing a leather jacket similar to that worn by the robber” | explaining “that such evidence may be unreliable and cannot be put in proper perspective by cross-examination of the person repeating it in court” | disallowing admission of identification testimony based on lineup conducted at any stage of the investigative process if unduly suggestive under due process standard of examining the totality of the surrounding circumstances | explaining identification procedure is unnecessarily suggestive if it “make[s] the resulting identifications virtually inevitable” | ignoring and suppressing exculpatory information about other suspects denied defendant’s right to due process | reversing a conviction based on eyewitness identification after successive suggestive lineups | recurring presence of same individual in successive lineups is unduly suggestive | finding unconstitutional an identification involving two lineups weeks apart, the only common member of which was the accused, and a one-on-one interview with witness and the accused, with prosecution but without defense counsel present | finding a “compelling example of unfair lineup procedures” when “[t]here were three men in the lineup. One was petitioner. He is a tall man-close to six feet in height. The other two men were short-five feet, five or six inches.” | repeated lineups in which defendant was the only common suspect held to violate standard set out in Stovall | repeated lineups in which defendant was the only common suspect held to violate standard set out in Stovall | where repetitive, suggestive lineups changed an uncertain identification to a certain identification, admission was error | where repetitive, suggestive lineups changed an uncertain identification to a certain identification, admission was error | identification obtained after victim viewed defendant in two lineups and one-on-one violated due process where defendant was only person in both lineups | “The reliability of properly admitted eyewitness identification, like the credibility of the other parts of the prosecution’s case is a matter for the jury.” | “The reliability of properly admitted eyewitness identification ... is a matter for the jury.” | suggestive lineup procedures used by police “so undermined the reliability of the eyewitness identification as t
Citator
- Cited by
- 496 opinions
delivered the opinion of the Court.
Petitioner was charged by information with the armed robbery of a Western Union office in violation of California Penal Code § 211a. The day after the robbery one of the robbers, Clay, surrendered to the police and implicated Foster and Grice. Allegedly, Foster and Clay had entered the office while Grice waited in a car. Foster and Grice were tried together. Grice was acquitted. Foster was convicted. The California District Court of Appeal affirmed the conviction; the State Supreme Court denied review. We granted certiorari, limited to the question whether the conduct of the police lineup resulted in a violation of petitioner’s constitutional rights. 390 U. S. 994 (1968).
Except for the robbers themselves, the only witness to the crime was Joseph David, the late-night manager of the Western Union office.- After Foster had been arrested, David was called to the police station to view a lineup. There were three men in the lineup. One was petitioner. He is a tall man — close to six feet in height. The other two men were short — five feet, five or six inches. Petitioner wore a. leather jacket which David said was similar to the one he had seen underneath the coveralls worn by the robber. After seeing this lineup, David could not positively identify petitioner as the robber. He “thought” he was the man, but he was not sure. David then asked to speak to petitioner, and petitioner was brought into an office and sat across from David at a table. Except for prosecuting officials there was no one else in the room. Even after this one-to-one confrontation David still was uncertain whether petitioner was one of the robbers: “truthfully — I was not sure,” he testified at trial. A week or 10 days later, the police arranged for David to view a second lineup. There were five men in that lineup. Petitioner was the only person in the second lineup who had
At trial, David testified to his identification of petitioner in the lineups, as summarized above. He also repeated his identification of petitioner in the courtroom. The only other evidence against petitioner which concerned the particular robbery with which he was charged was the testimony of the alleged accomplice Clay.1
In United States v. Wade, 388 U. S. 218 (1967), and Gilbert v. California, 388 U. S. 263 (1967), this Court held that because of the possibility of unfairness to the accused in the way a lineup is conducted, a lineup is a “critical stage” in the prosecution, at which the accused must be given the opportunity to be represented by counsel. That holding does not, however, apply to petitioner’s case, for the lineups in which he appeared occurred before June 12, 1967. Stovall v. Denno, 388 U. S. 293 (1967). But in declaring the rule of Wade and Gilbert to be applicable only to lineups conducted after those cases were decided, we recognized that, judged by the “totality of the circumstances,” the conduct of identification procedures may be “so unnecessarily suggestive and conducive to irreparable mistaken identification” as to be a denial of due process of law. Id., at 302. See Simmons v. United States, 390 U. S. 377, 383 (1968); cf. P. Wall, Eye-Witness Identification in Criminal Cases; J. Frank & B. Frank, Not Guilty; 3 J. Wigmore, Evidence § 786a (3d ed. 1940); 4, id., § 1130.
Judged by that standard, this case presents a compelling example of unfair lineup procedures.2 In the
The suggestive elements in this identification procedure made it all but inevitable that David would identify petitioner whether or not he was in fact “the man.” In effect, the police repeatedly said to the witness, “This is the man.” See Biggers v. Tennessee, 390 U. S. 404, 407 (dissenting opinion). This procedure so undermined the reliability of the eyewitness identification as to violate due process.
In a decision handed down since the Supreme Court of California declined to consider petitioner’s case, it reversed a conviction because of the unfair makeup of a lineup. In that case, the California court said: “[W]e do no more than recognize . . . that unfairly constituted lineups have in the past too often brought about the conviction of the innocent.” People v. Caruso, 68 Cal. 2d 183, 188, 436 P. 2d 336, 340 (1968). In the present case the pretrial confrontations clearly were so arranged as to make the resulting identifications virtually inevitable.
Reversed and remanded.
Mr. Justice White, with whom Mr. Justice Harlan and Mr. Justice Stewart concur, being unwilling in this case to disagree with the jury on the weight of the evidence, would affirm the judgment.California law requires that an accomplice’s testimony be corroborated. California Penal Code § 1111. There was also evidence that Foster had been convicted for a similar robbery committed six years before.
The reliability of properly admitted eyewitness identification, like the credibility of the other parts of the prosecution’s case is a matter for the jury. But it is the teaching of Wade, Gilbert, and