Tuesday, November 5, 2013

Neil v. Biggers case brief

Neil v. Biggers case brief summary
409 U.S. 188 (1972)

CASE SYNOPSIS
Petitioner, the State of Tennessee, appealed the judgment of the United States Court of Appeals for the Sixth Circuit, which affirmed the district court's holdings that respondent's federal habeas corpus action was not barred by 28 U.S.C.S. § 2244(c) and that the station-house identification of respondent was so suggestive as to violate due process.

CASE FACTS
Respondent brought a federal habeas corpus action in the wake of his conviction for rape. Petitioner, the State of Tennessee, argued that respondent's claims were barred by 28 U.S.C.S. § 2244(c) because respondent's claims had already been adjudicated by the U.S. Supreme Court on certiorari. The district court held that respondent's claims were not barred and that the station-house identification procedure was so suggestive as to violate due process. The court of appeals affirmed.

DISCUSSION
  • The U.S. Supreme Court affirmed in part, reversed in part, and remanded. 
  • The Court held that 28 U.S.C.S. § 2244(c) did not bar claims on which the judgment of a state court stood because of the absence of a majority position in the Court and that the lower courts thus properly reached the merits. 
  • The Court held, however, that the identification was reliable even though the confrontation procedure was suggestive. 
  • The Court found that the victim of the rape spent a considerable period of time with her assailant and that her description to the police was more than ordinarily thorough.
CONCLUSION

The Court affirmed in part, reversed in part, and remanded. The Court affirmed the judgment that the federal habeas corpus statute did not bar claims on which the judgment of a state court stood because of the absence of a majority position in the Court. The Court held, however, that the identification of respondent was reliable and reversed the judgment that the station-house identification was so suggestive as to violate due process.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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