People of the State of Michigan v. Aaron Xavier Johnson

Michigan Supreme Court · December 4, 2020 · No. 159924

Summary

**Key Legal Topics:** Suggestive identification procedures; showups; three-part test for admissibility (suggestive, unnecessary, unreliable); reliability factors under *Neil v Biggers*; police deterrence. **Holding:** The Michigan Supreme Court denied leave to appeal, concluding the identification was reliable under the *Sammons* test despite an unnecessarily suggestive showup (defendant in police car). The concurrence criticized the police for routinely using unnecessary showups and the Court of Appeals for appearing to sanction the practice, but agreed the identification was reliable under existing law.

Questions Presented

  1. Whether the identifications were the product of an unnecessarily suggestive showup

Disposition

writ_denied

Cases Cited (6)

  • People v. Sammons, 505 Mich. 31 (2020)(positive)
  • Perry v. New Hampshire, 565 U.S. 228 (2012)(positive)
  • Stovall v. Denno, 388 U.S. 293 (1976)(positive)
  • Manson v. Brathwaite, 432 U.S. 98 (1977)(positive)
  • Ex parte Frazier, 729 So. 2d 253 (Ala. 1998)(positive)
  • Neil v. Biggers, 409 U.S. 188 (1972)(positive)

Cited In (0)

No citing cases on record yet.

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