Tuesday, November 5, 2013

Foster v. California case brief

Foster v. California case brief summary
394 U.S. 440 (1969)

Defendant was convicted for armed robbery. The Court of Appeals of California, Fifth Appellate District, affirmed the conviction. The state supreme court denied review. Defendant filed a petition for writ of certiorari. The United States Supreme Court granted certiorari.

After defendant was arrested for armed robbery, two lineups were held. The witness could not positively identify defendant as one of the robbers, although he "thought" that defendant was one. The police brought defendant into a room so that the witness could speak to him. Even after the one-on-one confrontation, the witness was still uncertain whether defendant was the robber; however, he identified defendant in court, and defendant was convicted. The Court granted certiorari to determine if the police lineup had violated defendant's constitutional rights.

  • The Court held that the lineup had to be judged by the totality of the circumstances. 
  • The Court found that defendant's lineup presented a compelling example of unfair lineup procedures because the suggestive elements in the identification procedure made it all but inevitable that the witness would identify defendant whether or not he was in fact the robber. 
  • In reversing defendant's conviction and remanding the case, the Court concluded that the procedure so undermined the reliability of the eyewitness identification that it violated defendant's right to due process.

The Court reversed defendant's conviction for robbery and remanded the cause for further proceedings not inconsistent with the Court's opinion.

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

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