State v. Clopten

Rule of Law:

Expert testimony regarding the reliability of eyewitness identification should be routinely admitted in cases involving the identification of strangers where specific factors affecting accuracy, such as stress or weapon focus, are present.

Facts:

• Tony Fuailemaa was shot and killed outside a Salt Lake City nightclub following a rap concert.
• Police pursued a vehicle leaving the scene and arrested Deon Clopten, who was driving, along with three other passengers.
• Clopten claimed that another passenger, Freddie White, was the actual shooter.
• The State lacked forensic evidence, such as fingerprints or DNA, linking Clopten to the murder weapon.
• The prosecution's case relied heavily on the testimony of two eyewitnesses, Pantoja and Valdez, who identified Clopten as the shooter.
• The shooting occurred at night under chaotic circumstances involving high stress, the presence of a weapon, and cross-racial identification issues.
• The defense attempted to call Dr. Dodd, an expert on eyewitness memory, to explain how factors like 'weapon focus' and stress can distort identification accuracy.
• Dr. Dodd intended to testify that an eyewitness's confidence in their identification does not necessarily correlate with their accuracy.

Procedural Posture:

• The State charged Clopten with first-degree murder in the district court.
• The district court granted the State's motion to exclude the defense's expert witness on eyewitness identification.
• The jury convicted Clopten of first-degree murder.
• Clopten appealed the conviction to the Utah Court of Appeals.
• The Utah Court of Appeals affirmed the conviction but invited the Supreme Court to revisit the issue.
• Clopten petitioned the Utah Supreme Court for certiorari review.