Young v. State

[CRIMINAL LAW]

In Young v. State,[1] the supreme court held that the Manson v. Brathwaite[2] test for evaluating eyewitness identifications failed to account for due process reliability concerns and thus devised a new test requiring evidence of a system variable of suggestiveness to justify a hearing, followed by a totality of circumstances analysis of system and estimator variables affecting the identification’s reliability at the hearing.[3] Young was charged with attempted murder and misconduct involving weapons.[4] He challenged the admission of two eyewitness identifications, claiming that they were unnecessarily suggestive, but the superior court found neither unnecessarily suggestive.[5] While the court of appeals disagreed with the superior court as to the first identification, it found the error to be harmless.[6] Young petitioned to the Alaska supreme court, arguing that the identifications were inadmissible under the current test and that the due process clause of the Alaska Constitution required adopting a more protective eyewitness identification admissibility test.[7] The supreme court evaluated the identifications under the Brathwaite test, which first requires a determination that the identification be unnecessarily suggestive and then considers the totality of the circumstances as to reliability.[8] The court found that the first identification failed the test,[9] while the second identification passed.[10] The court noted, however, that the Brathwaite test emphasizes the reliability of an identification based heavily on the certainty of the witness—which may directly correlate with the process’s suggestiveness.[11] The court proposed a new test requiring consideration of system and estimator variables contributing to an identification’s reliability and necessity, rather than a preemptive qualification of outright unnecessary suggestiveness.[12] The supreme court affirmed the court of appeals,[13] but overturned the Brathwaite test for evaluating eyewitness identifications and devised a new test requiring evidence of a system variable of suggestiveness to justify a hearing, followed by a totality of the circumstances analysis of system and estimator variables affecting the identification’s reliability at the hearing.[14]

[1] 374 P.3d 395 (Alaska 2016).
[2] 432 U.S. 98 (1977).
[3] Young, 374 P.3d at 426–27.
[4] Id. at 399–400.
[5] Id. at 401.
[6] Id. at 403.
[7] Id. at 399.
[8] Id. at 406.
[9] Id. at 409.
[10] Id. at 412.
[11] Id. at 426.
[12] Id. at 427.
[13] Id. at 399.
[14] Id. at 426–27.

Young v. State

[CRIMINAL LAW]

In Young v. State,[1] the supreme court held that the Manson v. Brathwaite[2] test for evaluating eyewitness identifications failed to account for due process reliability concerns and thus devised a new test requiring evidence of a system variable of suggestiveness to justify a hearing, followed by a totality of circumstances analysis of system and estimator variables affecting the identification’s reliability at the hearing.[3] Young was charged with attempted murder and misconduct involving weapons.[4] He challenged the admission of two eyewitness identifications, claiming that they were unnecessarily suggestive, but the superior court found neither unnecessarily suggestive.[5] While the court of appeals disagreed with the superior court as to the first identification, it found the error to be harmless.[6] Young petitioned to the Alaska supreme court, arguing that the identifications were inadmissible under the current test and that the due process clause of the Alaska Constitution required adopting a more protective eyewitness identification admissibility test.[7] The supreme court evaluated the identifications under the Brathwaite test, which first requires a determination that the identification be unnecessarily suggestive and then considers the totality of the circumstances as to reliability.[8] The court found that the first identification failed the test,[9] while the second identification passed.[10] The court noted, however, that the Brathwaite test emphasizes the reliability of an identification based heavily on the certainty of the witness—which may directly correlate with the process’s suggestiveness.[11] The court proposed a new test requiring consideration of system and estimator variables contributing to an identification’s reliability and necessity, rather than a preemptive qualification of outright unnecessary suggestiveness.[12] The supreme court affirmed the court of appeals,[13] but overturned the Brathwaite test for evaluating eyewitness identifications and devised a new test requiring evidence of a system variable of suggestiveness to justify a hearing, followed by a totality of the circumstances analysis of system and estimator variables affecting the identification’s reliability at the hearing.[14]

[1] 374 P.3d 395 (Alaska 2016).
[2] 432 U.S. 98 (1977).
[3] Young, 374 P.3d at 426–27.
[4] Id. at 399–400.
[5] Id. at 401.
[6] Id. at 403.
[7] Id. at 399.
[8] Id. at 406.
[9] Id. at 409.
[10] Id. at 412.
[11] Id. at 426.
[12] Id. at 427.
[13] Id. at 399.
[14] Id. at 426–27.