State v. Traylor, 360 S.C. 74

Summary

The Supreme Court of South Carolina reviewed the suggestiveness and reliability of a photographic lineup in which three victims viewed photographs in the same room. The court held that the procedure was patently suggestive but did not create a substantial likelihood of irreparable misidentification. It also held that admitting mug-shot photographs was error because the State lacked a demonstrable need, but affirmed the convictions because the error was not prejudicial.

Holdings

1. The lineup procedure was patently and blatantly suggestive because the three victims viewed the photographs simultaneously in the same room, but the identifications remained reliable under the totality of the circumstances and did not create a substantial likelihood of irreparable misidentification. The identifications were therefore admissible.
2. The trial court erred by admitting the mug-shot photographs because the State had no demonstrable need to introduce them. However, the error was not prejudicial under the circumstances because the testimony and examination explained the photograph's origin without implying that Traylor had committed prior bad acts; therefore, the convictions were affirmed.

Questions Presented

1. Whether the photographic lineup procedure was unduly suggestive and whether the resulting identifications were unreliable and therefore inadmissible under due process.
2. Whether the trial court committed reversible error by admitting the lineup photographs, which were mug shots, into evidence.

Disposition

reversed