Manson v. Brathwaite Case Brief

Why is the case important?

A suggestive identification was challenged as violative of the due process clause of the Fourteenth Amendment of the United States Constitution (“Constitution”).

Facts of the case

An undercover police officer bought drugs from a narcotics vendor. The officer saw the vendor up close for several minutes. The officer described the vendor to another officer who obtained a photograph of Nowell A. Brathwaite and gave it to the first officer. The officer identified the Brathwaite as the narcotics vendor. At trial, the photograph was admitted as evidence and the officer again identified Brathwaite as the vendor. A jury convicted Brathwaite of possession and sale of heroin. The Connecticut Supreme Court affirmed. Brathwaite then filed a petition for a writ of habeus corpus in district court. The district court dismissed the petition, but the U.S. Court of Appeals for the Second Circuit reversed, holding that the officer’s identification was unreliable and the method of identification from a single photograph was unnecessarily suggestive.

Question

Whether the due process clause of the Fourteenth Amendment of the Constitution compels the exclusion, in a state criminal trial, apart from any consideration of reliability, of pretrial identification evidence obtained by a police procedure that was both suggestive and unnecessary?

Answer

Reliability is the linchpin in determining the admissibility of identification testimony. Factors to be considered include the opportunity of the witness to view the criminal at the time of the crime, the degree of attention paid by the witness, accuracy of the prior description, level of certainty, and the time between the crime and the confrontation. These factors should be weighed against the effect of the suggestive identification itself.

Conclusion

The Supreme Court of the United States held that due process did not compel the exclusion of pretrial identification evidence obtained by a suggestive and unnecessary police identification procedure so long as, under the totality of the circumstances, the identification was reliable. Under the circumstances of Brathwaite’s case, the undercover officer’s identification was sufficiently reliable to permit its admission into evidence. The Court 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 Brathwaite’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 the case, there was very substantial likelihood of irreparable misidentification.

  • Case Brief: 1977
  • Petitioner: John R. Manson, Commissioner of Correction of the State of Connecticut
  • Respondent: Nowell A. Brathwaite
  • Decided by: Burger Court

Citation: 432 US 98 (1977)
Argued: Nov 29, 1976
Decided: Jun 16, 1977
Granted May 3, 1976