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State v. Henderson

Supreme Court of New Jersey
27 A.3d 872 (N.J. 2011) (2011)
ELI5:

Rule of Law:

The framework for admitting eyewitness identification evidence must be revised to incorporate modern scientific findings on human memory. When a defendant shows some evidence of suggestiveness related to a system variable (police action), a pretrial hearing must be held where the court considers all relevant system and estimator variables to determine if there is a very substantial likelihood of irreparable misidentification.


Facts:

  • On January 1, 2003, Rodney Harper was shot and killed in an apartment, an event witnessed by James Womble.
  • Womble, who had been drinking alcohol and smoking crack cocaine, was in a small, dark hallway with the shooter's accomplice, a stranger to him, who pointed a gun at him.
  • Ten days later, Womble gave police a statement and agreed to view a photographic array.
  • During the identification procedure, Womble narrowed the array to two photos but told the administrator he was not 100 percent sure and seemed indecisive.
  • The two primary investigating officers, who were not supposed to be involved in the procedure, then entered the room to speak with Womble.
  • The officers encouraged Womble to "focus" and "do what you have to do," assuring him of police protection from any threats.
  • After the officers left, the administrator showed Womble the array again, and this time Womble identified Larry Henderson, exclaiming, "That's the mother [------] there."

Procedural Posture:

  • Larry Henderson was indicted by a grand jury in Camden County.
  • Henderson filed a motion to suppress the photo identification evidence, and the trial court conducted a Wade hearing.
  • The trial court found the identification procedure was not impermissibly suggestive and ruled the evidence admissible.
  • A jury convicted Henderson of reckless manslaughter, aggravated assault, and weapons charges.
  • Henderson, as appellant, appealed to the New Jersey Superior Court, Appellate Division.
  • The Appellate Division reversed Henderson's conviction, holding that the officers' actions created a presumption of impermissible suggestiveness, and remanded for a new Wade hearing.
  • The State, as petitioner, sought certification from the Supreme Court of New Jersey, which was granted.
  • The Supreme Court of New Jersey remanded the case to a Special Master for a plenary hearing to create a record on the current scientific evidence regarding eyewitness identification.

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Issue:

Does the Manson/Madison framework for assessing the admissibility of eyewitness identification evidence remain valid and appropriate under the New Jersey Constitution in light of extensive scientific research on human memory and the factors affecting identification reliability?


Opinions:

Majority - Chief Justice Rabner

No. The Manson/Madison framework for assessing eyewitness identification evidence does not fully meet its goals, as it fails to provide an adequate measure for reliability, does not sufficiently deter inappropriate police conduct, and overstates a jury's ability to evaluate eyewitness testimony. The court concludes that the vast body of scientific research on human memory that has emerged since Manson was decided demonstrates that memory is malleable and that numerous variables can lead to misidentifications. The old test is flawed because it only considers estimator variables after a finding of 'impermissibly suggestive' police conduct, relies on witness self-reporting which can be skewed by the suggestive procedure itself, and may unintentionally reward suggestive police practices by increasing witness confidence. Therefore, the framework must be revised to allow for a broader inquiry into all factors affecting reliability.



Analysis:

This landmark decision fundamentally alters the legal standard for the admissibility of eyewitness identification in New Jersey, moving away from the decades-old, restrictive Manson test. By requiring courts to consider a wide range of scientifically-validated system and estimator variables, Henderson makes it easier for defendants to secure a pretrial reliability hearing and challenges the long-held assumption that jurors can intuitively assess the accuracy of an identification. The ruling's emphasis on science-based jury instructions is expected to significantly impact trial practice and has positioned New Jersey as a leader in reforming eyewitness law, influencing other jurisdictions to reconsider their own standards.

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