Why is the case important?
The constitutionality of a station house identification by the victim of a rape was at issue.
Facts of the case
“A Tennessee state court convicted Archie Biggers in the rape of Margaret Beamer. The only major evidence against him was Ms. Beamer’s identification several weeks after the incident at a police station “show up”. The “show up” was similar to a line up, but contained the suspect alone. The police officer also had the suspect say phrases Ms. Beamer heard her attacker say on the night of the rape. Ms. Beamer said she had “no doubt” that Biggers was her attacker. The Tennessee Supreme Court upheld the conviction. The U.S. Supreme Court affirmed by an equally divided court.Biggers then filed a writ of habeas corpus, which the district court granted, holding that the Supreme Court affirming by an equally divided court did not bar the writ. The court also held that the “show up” procedure was so suggestive that it violated due process. The U.S. Court of Appeals for the Sixth Circuit affirmed.”
Whether the station house identification procedure was so suggestive (not reliable) to violate due process?
“The majority observed first of all, it is apparent that the primary evil to be avoided is ‘a very substantial likelihood of irreparable misidentification.’Â
“On certiorari, the United States Supreme Court reversed in part and remanded the case. The Court unanimously held that although the federal habeas corpus statute would preclude relitigation of issues “”actually adjudicated by the Supreme Court”” in a prior criminal proceeding, the Supreme Court’s affirmance by an equally divided court did not constitute such an actual adjudication as to fall within the bar
- Case Brief: 1972
- Petitioner: William S. Neil, Warden of the Tennessee State Penitentiary
- Respondent: Archie Nathaniel Biggers
- Decided by: Burger Court
Citation: 409 US 188 (1972)
Argued: Oct 18 – 19, 1972
Decided: Dec 6, 1972
Granted Feb 28, 1972