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In the typical "fruit of the poisonous tree" case, the challenged evidence was acquired by the police after some initial Fourth Amendment violation, and the question before a court is whether the chain of causation proceeding from the unlawful conduct has become so attenuated or has been interrupted by some intervening circumstance so as to remove the "taint" imposed upon that evidence by the original illegality. Thus, most cases begin with the premise that the challenged evidence is in some sense the product of illegal governmental activity.
Immediately after being assaulted and robbed at gunpoint, the victim notified the police and gave them a full description of her assailant. Several days later, Respondent Crews, who matched the suspect's description, was seen by the police around the scene of the crime. After an attempt to photograph him proved unsuccessful, Crews was taken into custody, ostensibly as a suspected truant from school, and was detained at police headquarters, where he was briefly questioned, photographed, and then released. Thereafter, the victim identified Crews’ photograph as that of her assailant. Crews was again taken into custody and at a court-ordered lineup was identified by the victim. Crews was then indicted for armed robbery and other offenses. On Crews’ pretrial motion to suppress all identification testimony, the trial court found that Crews’ initial detention at the police station constituted an arrest without probable cause and accordingly ruled that the products of that arrest -- the photographic and lineup identifications -- could not be introduced at trial, but further held that the victim's ability to identify Crews in court was based upon independent recollection untainted by the intervening identifications and that therefore such testimony was admissible. At trial, the victim once more identified Crews as her assailant, and Crews was convicted of armed robbery. The District of Columbia Court of Appeals reversed, holding that the in-court identification testimony should have been excluded as a product of the violation of Crews’ Fourth Amendment rights.
Was the in-court identification of an accused by a victim of crime suppressible as fruit of accused's unlawful arrest?
The Court reversed the suppression of the in-court identification and reinstated the conviction. The Court held that the in-court identification was not the product of illegal government activity. The Court stated that this was not a case in which Crews’ identity was discovered or the victim's cooperation secured only as a result of an unlawful search or arrest. Crews’ identity was known long before there was any official misconduct, and his presence in court was not traceable to any Fourth Amendment violation.