CRIMINAL LAW
Court of Appeals of Alaska (2023)
Johanna Crisman
In Baines v. State, 535 P.3d 899 (Alaska Ct. App. 2023), the court of appeals held that the questionable admission of showup identifications are not grounds to reverse conviction if remaining evidence is sufficient to support the jury’s verdict. (Id.) Baines was convicted following a jury trial of multiple crimes in connection with car break-ins. (Id. at 901). Five different people, including Pulis and Fullwood, had reported someone had broken into their cars in the same general area as where Baines had been apprehended. (Id. at 902). Pulis and Fullwood, in separate showup identifications, both identified Baines as the man who had pointed a gun at them and broken into their vehicles. (Id. at 902). On appeal, Baines argued the identifications were unreliable under the test the Alaska Supreme Court adopted in Young v. State. (Id. at 905). The court of appeals concluded that the superior court erred in considering independent evidence of Baines’ guilt when assessing the admissibility of their identifications. (Id. at 907). However, because substantial and conclusive independent evidence established that Baines was the person who broke into Pulis’ and Fullwood’s car, any error in declining to suppress the identifications were harmless beyond a reasonable doubt. (Id. at 908). As a result, the court of appeals declined to definitively resolve whether the identifications were admissible under a proper application of the Young test. (Id. at 907). Accordingly, the court of appeals held that the questionable admission of showup identifications are not grounds to reverse conviction if remaining evidence is sufficient to support the jury’s verdict. (Id. at 901).
