Watts v. State

I cannot agree that the testimony of the police officer that the complainant had identified defendant in a pre-trial photographic lineup was admissible because the complainant never testified that she had *942identified defendant’s photograph before trial. Neither can I agree that the officer’s testimony was admissible because complainant’s testimony had been challenged. Instead, I would hold that because complainant’s identification testimony was unim-peached, the officer’s testimony was improper bolstering, requiring reversal. Consequently, I must dissent.

The majority first reasons that the…