State v. Heald

The primary issue in this case is whether the trial court impermissibly allowed into evidence certain out-of-court identifications of a criminal defendant based on an array of photographs.

Shortly before midnight on April 14, 1978, John Reid stood waiting for his wife in front of the lobby entrance of the American Inn in Nashua. While waiting, Mr. Reid noticed a small car containing two men parked near the entrance. He later testified that he noticed the car and its occupants because the driver kept revving the engine and the passenger door was ajar. After a few minutes, Mr. Reid’s wife…