Evidence

United States v. Crews — Study Notes

United States v. Crews, 445 U.S. 463 (1980)

Study notes for United States v. Crews: professor notes, cold call prep, exam angles, and memory aids.

A victim's in-court identification can be admissible if it is based on independent observation rather than solely on evidence obtained through unlawful police conduct.
Professor Notes

The Supreme Court's decision in United States v. Crews underscores the importance of distinguishing between evidence gained illegally due to police misconduct and the independent sources of evidence that may be unaffected by such taint. In this case, the victim's in-court identification was deemed permissible despite the fact that Crews' photograph was obtained through an unlawful detention. Professors may emphasize the Court's reasoning that the identification was based on the victim's original observations during the criminal act, showcasing the 'independence' of such an identification from the prior illegal conduct of law enforcement.

This case also illustrates the broader implications of the exclusionary rule, especially concerning its application to in-court identifications. The ruling reinforces the principle that not all evidence linked to an illegality is automatically inadmissible if it can be proven to be derived from a legitimate source independent of that illegality. Professors might challenge students to consider the potential repercussions of this distinction on the balance of police powers and citizens' rights to not be wrongly identified due to procedural missteps.

Cold Call Prep
  1. 1Explain the significance of the victim's observation during the crime in determining the admissibility of identification.
  2. 2What precedent does this case set for the relationship between unlawful police conduct and in-court identifications?
  3. 3How does the concept of independent sources play a role in judicial determinations of admissibility?
  4. 4Discuss the implications of the ruling on the exclusionary rule in general.
  5. 5What might have been the outcomes if the victim had not observed the defendant during the crime?
Mnemonic Device

I vs. I: Independent observation weighs more than Illegal action.

Distinguish From
CaseDistinction
Mapp v. OhioMapp dealt primarily with the unlawful search and seizure of evidence, leading to a broader application of the exclusionary rule compared to the specific identification issues in Crews.
Neil v. BiggersNeil involved the reliability of eyewitness testimony under suggestive circumstances, contrasting with Crews, where the identification was based on prior independent observation.
Policy Arguments

For the Rule

Permitting in-court identifications that are independent ensures that genuine evidence of guilt is not discarded due to police errors, promoting justice.

Against the Rule

Allowing such identifications might encourage police to conduct unlawful detentions without regard for constitutional protections.

Class Discussion Points
  • What is the appropriate balance between police procedures and individual rights in the context of the exclusionary rule?
  • How do eyewitness identifications influence jury perceptions and outcomes in criminal trials?
  • Discuss the implications of this ruling for future cases involving unlawful detentions and evidentiary standards.
Exam Angle

This case frequently appears on exams in discussions of the exclusionary rule and the issue of in-court identifications, particularly in how the Court navigates between procedural missteps by law enforcement and the evidentiary value of eyewitness accounts.

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