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State v. Henderson
New Jersey Supreme Court
208 N.J. 208, 27 A.3d 872 (2011)
Larry Henderson (defendant) was suspected of murdering Rodney Harper. During the investigation, James Womble, who witnessed the murder, participated in the state’s (plaintiff) photo array and identified Henderson. When Womble was first shown the array of eight photos, he narrowed the photos down to two possible pictures and told investigators he was not sure which one was the individual he had seen. The investigators saw that Womble was nervous and upset and told him to calm down and focus. The investigators reshuffled the photos for a second attempt and Womble identified Henderson’s photo. The trial court held a hearing to determine whether the photo-array results were admissible into evidence applying the Manson/Madison test, which requires the court to determine whether the identification was impermissibly suggestive and, if so, whether the results are still admissible based on various reliability factors. The trial court ruled the evidence admissible, holding that there was no impermissibly suggestive behavior. The jury convicted Henderson of reckless manslaughter. Henderson appealed. The court of appeals reversed, holding that the identification procedure was impermissibly suggestive and remanded the case for a determination of whether the results were still admissible based on the reliability factors in the Manson/Madison test. The state petitioned the New Jersey Supreme Court to review whether the Manson/Madison test was the appropriate framework to determine the admissibility of eyewitness-identification testimony. The court granted the state’s petition.
Rule of Law
Holding and Reasoning (Rabner, C.J.)
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