People v. Lane

OPINION OF THE COURT

Ellen M. Yacknin, J.

Introduction

Law enforcement officers often use identification procedures, such as photograph displays, lineups, and showups, to assist a witness’s out-of-court identification of a perpetrator when the witness does not personally know the perpetrator. Under New York State law, when the People intend to elicit an in-court identification of a defendant from a witness who has previously identified the defendant as the alleged perpetrator at a police-arranged identification, the People must provide notice of the witness’s previous identification to the…