Sunday, November 3, 2013

United States v. Wade case brief

United States v. Wade case brief summary
388 U.S. 218 (1967)

CASE SYNOPSIS
Certiorari was granted in a case from the United States Court of Appeals for the Fifth Circuit, which reversed respondent's conviction and ordered a new trial that was to exclude courtroom identifications because the lineup that had been held in the absence of defense counsel violated respondent's Sixth Amendment right to assistance of counsel.

CASE FACTS
The employees of a robbed bank identified respondent in a lineup that had been conducted without counsel being present. At trial, the employees pointed to respondent when asked to identify the robber. Respondent was convicted, but the court of appeals reversed his conviction and ordered a new trial, excluding the courtroom identifications. The court of appeals concluded that the lineup violated respondent's Sixth Amendment right to assistance of counsel.

DISCUSSION
  • The Court remanded the action to the court of appeals to enter a new judgment vacating respondent's conviction, until a hearing could determine whether the in-court identifications had independent origins. 
  • The post-indictment lineup was a critical stage of the proceedings, so respondent was entitled to have his attorney present. 
  • Based on the record, the Court could not determine whether the courtroom identifications should be excluded. 
  • Evidence had to be presented as to whether the in-court identifications were based on observations or the lineup.

CONCLUSION

The Court remanded the action to the court of appeals, with directions to enter a judgment vacating respondent's conviction and remanding the case to the district court for a determination as to whether the courtroom identifications had independent origins. The Court was unable to determine whether the witness's courtroom identifications should have been excluded from evidence.

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

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