Stovall v. Denno

Stovall v. Denno Case Brief

United States Supreme Court
388 U.S. 293 (1967)

ISSUE: Did police violate D's due process rights by displaying him singly in a hospital room before the victim a day after her surgery and the victim made a positive ID of D?
HOLDING: No.
FACTS:
  • Dr. and Mrs. Behrendt were stabbed in their kitchen by an intruder, and Dr. B died
  • Police found a shirt with keys in the pocket which they traced to D
  • D was then arrested
PROCEDURAL HISTORY:
  • Arraignment was held but was then postponed until D could retain counsel
  • Police took D to Mrs. B's hospital room the day after a major surgery so that she could ID him
    • D was the only black person in the room
    • D was forced to say some words that no one was sure if the attacker even said
    • Mrs. B ID'ed D and then also made an in-court ID
  • D was convicted of murder and sentenced to death; aff'd by Ct. App.
  • D, proceeding pro se, brought a habeas petition for violation of his 5th , 6th, and 14th Amdt. rights b/c he was compelled to submit to the hospital room confrontation w/o assistance of counsel
    • Dist. Ct. dismissed petition
    • Ct. App. fist reversed, but then affirmed en banc
REASONING:
  • No DPC violation: A claim violation of due process of law in the conduct of a confrontation depends on the totality of the circumstances surrounding it, and the record here reveals that showing D to Mrs. B in the hospital was imperative
    • Mrs. B was the only person who could exonerate D
    • Under the circumstances, a police station lineup would be out of the question
    • DPC forbids a lineup that is unnecessarily suggestive and conducive to irreparable mistaken identification
COMMENTS:
  • Miranda is only violated when a statement is used against a D at trial, not just when D was interrogated w/o Miranda rights
  • Stovall only relevant when the witness is likely to die soon, and it's necessary to do an immediate lineup to exonerate the suspect
    • Suggestive lineup like this is sometimes permissible
    • Single-person lineup is only permissible if the witness is literally about to die
OTHER CASES:
  • Foster v. California: D was shown to V in a each of 2 lineups. In the 1st lineup, D was 5-6 inches taller than all the other men and was wearing a leather jacket that was how the perp was dressed. In the 2nd lineup, D was the only person who was the same as before
    • HELD, the suggestive elements in the ID procedure made it all but inevitable that the witness would identify D whether or not he was in fact the man
    • = Violation of D's due process rights (only SCOTUS case to so hold thus far)

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