Legal Opinion

Leo v. State

Court of Special Appeals of Maryland

Decided December 18, 2025No. 2506/23Published

1Opinion of the Court

Reginald Lincoln Leo, Jr. v. State of Maryland, No. 2506, September Term, 2023. Opinion by Graeff, J. DUE PROCESS PROTECTIONS FOR EXTRAJUDICIAL IDENTIFICATIONS Due process protects the accused against the introduction of evidence of, or tainted by, unreliable pretrial identifications obtained through unnecessarily suggestive procedures. When appellant’s photo in a photo array included a minor difference in the background that was noticeable only on a close look, his photo did not “stand out” or “differ significantly” from the others in the group in a way that rendered the photo array…

2Cases cited37 opinions

  1. Simmons v. United StatesSupreme Court of the United States · 1968
  2. Neil v. BiggersSupreme Court of the United States · 1972
  3. Stovall v. DennoSupreme Court of the United States · 1967
  4. Perry v. New HampshireSupreme Court of the United States · 2012
  5. Dua v. Comcast Cable of Maryland, Inc.Court of Appeals of Maryland · 2002

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