People v. Williams, 85 N.Y.2d 889 (1995)
A showup identification is admissible when it is unavoidable due to the spontaneous and fast-paced nature of the encounter, and not the product of unduly suggestive police conduct.
Summary
This case addresses the admissibility of a showup identification where the encounter between the victim and the defendant was unplanned and occurred due to a series of spontaneous events. The Court of Appeals affirmed the lower court’s decision, holding that the showup was admissible because it was the product of a fast-paced, uncontrollable situation and not unduly suggestive police conduct. The court emphasized that the circumstances made the showup unavoidable.
Facts
The victim was raped and sodomized in the lobby of her apartment building. Twelve days later, items were stolen from her apartment. An individual contacted the victim claiming to have her passport and identification cards. A neighbor provided a description of the individual who was looking for the victim. Based on the neighbor’s description and the caller’s admission, the victim believed this person was her attacker. The victim, after consulting with the police, arranged to meet the individual outside a subway station to recover her property. Detectives transported her to the location. They saw an individual matching the victim’s description. The detectives followed the suspect into the subway, where a scuffle ensued. The detectives arrested him and found the victim’s stolen items. The victim then observed the detectives emerging from the station with the defendant and immediately identified him as her attacker. The victim confirmed this identification when a detective indicated that the defendant’s teeth were crooked, a feature she had repeatedly mentioned.
Procedural History
The trial court admitted the showup identification. The defendant was convicted. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether the showup identification procedure was unduly suggestive and therefore inadmissible as evidence.
Holding
No, because the showup identification procedure was unavoidable given the erratic circumstances of the detectives’ encounter with the defendant, and was the product of a fast-paced, uncontrollable situation.
Court’s Reasoning
The Court of Appeals reasoned that the showup identification was admissible because it was the result of a spontaneous and rapidly evolving situation. The detectives’ encounter with the defendant was unplanned, and the identification occurred as a direct result of the arrest. The Court emphasized that the circumstances made the showup unavoidable, distinguishing it from cases where police orchestrate suggestive identification procedures. The court cited People v. Rivera, 22 NY2d 453, 455, noting the admissibility of identifications in fast-paced, uncontrollable situations. The court also referenced People v. Dixon, 85 NY2d 218. Furthermore, the court deferred to the undisturbed findings of the lower courts, which involved mixed questions of law and fact supported by the record evidence, citing People v. Oeller, 82 NY2d 774, 775. The Court noted that, “Given the erratic circumstances of the detectives’ encounter with defendant, the resulting ‘showup’ identification procedure was unavoidable, the product of a fast-paced, uncontrollable situation.”