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Keywords

defendantappealhearingtestimonymotion
defendantappealhearingtestimony

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People v. Dixon, 85 N.Y.2d 218, 647 N.E.2d 1321, 623 N.Y.S.2d 813

Facts

On September 17, 1990, Harold Knowings was robbed by a group of men in Brooklyn. After the robbery, the transit police drove Knowings around the area in a marked police van to identify the perpetrators. During this canvassing, Knowings pointed out the defendant as one of the robbers, leading to the defendant's arrest and subsequent charges of robbery and assault. The defendant sought a Wade hearing to challenge the identification procedure, claiming it was unfair and created a substantial likelihood of misidentification.

At approximately 11:00 p.m. on September 17, 1990, complainant Harold Knowings was robbed by a group of men as he left a grocery store in Brooklyn.

Issue

Did the courts below properly conclude that the allegedly spontaneous nature of the identification rendered a Wade hearing regarding the procedure unnecessary?

The question we must decide is whether the courts below properly concluded that the allegedly spontaneous nature of an identification rendered a Wade hearing regarding the procedure unnecessary.

Rule

A Wade hearing is required to test identification testimony for taint arising from official suggestion during police-arranged confrontations between a defendant and an eyewitness.

The purpose of the Wade hearing is to test identification testimony for taint arising from official suggestion during 'police-arranged confrontations between a defendant and an eyewitness.'

Analysis

The court determined that the canvassing of the crime scene was a police-sponsored procedure aimed at obtaining an identification. The suppression court's summary denial of the defendant's motion for a Wade hearing was deemed improper because the identification could not be established as free from police suggestion. The court emphasized that the identification process must be scrutinized to ensure it does not lead to wrongful convictions due to suggestive practices.

Here, the canvassing of the crime area in the police car was an identification procedure undertaken at the 'deliberate direction of the State.'

Conclusion

The Court of Appeals modified the Appellate Division's order and remitted the case for a Wade hearing to determine if the identification procedure was tainted by police suggestiveness.

Accordingly, the order of the Appellate Division should be modified in accordance with this opinion and, as so modified, affirmed.

Who won?

The defendant prevailed in the appeal as the Court of Appeals ruled that a Wade hearing was necessary to assess the identification procedure.

The Court of Appeals held that: (1) canvassing crime scene of mugging was police-sponsored procedure conducted for purpose of obtaining identification, and (2) Wade hearing was required to determine whether identification was free from police suggestion.

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