Sunday, November 3, 2013

Manson v. Brathwaite case brief

Manson v. Brathwaite case brief summary
432 U.S. 98 (1977)

The government prosecuted respondent and he was convicted of possession and sale of her*in. The United States Court of Appeals for the Second Circuit reversed the dismissal of respondent's petition for habeas corpus relief, with instructions to issue the writ unless the government gave notice to retry respondent and the new trial occurred within a reasonable time. The government sought certiorari review.

Respondent, on a claim for habeas relief, proposed a per se rule of exclusion that he claimed was dictated by the demands of the Fourteenth Amendment's guarantee of due process.

  • The Court adopted the totality of the circumstances test and concluded that the criteria applicable in determining the admissibility of evidence offered by the prosecution concerning an identification were satisfactorily met and complied with in respondent's case. 
  • The Court reasoned that the factors that had to be considered included the opportunity of the witness to view respondent at the time of the crime, the witness' degree of attention, the accuracy of his prior description of the criminal, the level of certainty demonstrated at the confrontation, and the time between the crime and the confrontation. 
  • Against these factors was weighed the corrupting effect of the suggestive identification itself. 
  • The Court determined that it could not say that, under all the circumstances of respondent's case, there was very substantial likelihood of irreparable misidentification.


The judgment reversing the denial of respondent's motion for habeas corpus relief was reversed.

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

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