Hull v. State

Carol Lacey Hull was convicted of first degree robbery and was sentenced as a habitual offender to life imprisonment without possibility of parole. On appeal, she contends that the in-court identification by an eyewitness should have been excluded because that identification was the product of an unduly suggestive photographic array displayed to the witness prior to trial and had no independent basis of reliability.

FACTS

Shortly before 2:00 p.m. on Sunday, February 1, 1987, a lone male entered Stacey's Drugstore in Bay Minette and robbed the pharmacist at gunpoint of various drugs. The robber…