744 So. 2d 93 - State v. Brown’s Empirical Analysis
1999
Citation profile
3 state decisions
How this case has been cited
Cited by 3 later decisions — most recently June 2016
3 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Manson v. Brathwaite · 446 So. 2d 729 - State v. Prudholm · State v. Every · 684 So. 2d 74 - State v. Sterling · State v. Cooper
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In Manson [v. Brathwaite, 432 U.S. 98 , 97 S.Ct. 2243 , 53 L.Ed.2d 140 (1977) ] the Supreme Court set forth a five-factor test to determine whether an identification is reliable: (1) the opportunity of the witness to view the assailant at the time of the crime; (2) the witness’ degree of attention; (3) the accuracy of the witness’ prior description of the assailant; (4) the level of certainty demonstrated by the witness; and (5) the length of time between the crime and the confrontation.”
3 later decisions quote this exact passage“Based upon these sightings, LaVergne compiled two photographic line-ups, one of‘which included [defendant’s] photograph. Abadie testified he showed the line-ups to Cannon approximately' a month after the sales, and Cannon positively identified [defendant] as the seller. Cannon was unable to identify anyone in the other line-up. [[Image here]] Even assuming arguendo that the line-up was suggestive, we do not find the identification unreliable under the Manson factors. Agent Cannon was conducting an undercover narcotics transaction. He testified regarding his training in this field, and about this particular transaction. He stated he saw defendant clearly for seven to ten minutes and was careful to note her features because he assumed he would have to identify her again. He gave Agents Abadie and LaVergne a very detailed description of the defendant’s physical appearance and clothing immediately after the second purchase. From this description, and upon viewing the scene, Agent LaVergne was able to immediately recognize defendant. Even though he reported her hair as red, defendant admitted that she has several different colored hair pieces. Also, upon viewing the line-up, Agent Cannon identified defendant immediately and positively. Lastly, Agent Cannon’s inability to identify anyone from the second male line-up bolsters the reliability of his selection of defendant; he did not identify anyone because he was not certain. Thus, under the totality of the circumstances, Agent Cann”
1 later decision quote this exact passagee.g. State v. Flemming
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.