State v. Martinez
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Summary

The NM Supreme Court held that the federal Manson test didn't protects against unreliable eyewitness identifications, adopting a new due process framework grounded in modern memory research and system and estimator variables.

2020 | State Juristiction

State v. Martinez

Keywords eyewitness identification; due process; memory research; system variables; estimator variables; unreliable identification
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Summary

The New Mexico Supreme Court determined that the federal Manson test does not adequately protect against unreliable eyewitness identifications. In response, the court adopted a new due process framework. This new framework is based on current research into memory and considers both system variables (factors within the control of the justice system) and estimator variables (factors not within the control of the justice system but relevant to an eyewitness's account).

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Summary

The New Mexico Supreme Court determined that the federal Manson test did not provide adequate protection against unreliable eyewitness identifications. As a result, the Court adopted a new due process framework. This new framework is based on current research concerning memory and considers both system and estimator variables related to eyewitness identification.

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Summary

The New Mexico Supreme Court decided that the federal Manson test does not adequately protect against eyewitness identifications that are not reliable. The court adopted a new due process framework. This new framework is based on current research about memory and factors that can influence identification.

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Summary

The New Mexico (NM) Supreme Court decided that the old federal test for eyewitnesses was not good enough. This old test did not protect against mistakes when people identified someone they saw.

The Court is now using a new way to look at these cases. This new way is based on how people's memories actually work. It also looks at different things that can make an eyewitness identification more or less reliable.

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Footnotes and Citation

Cite

State v. Martinez, 478 P.3d 880 (2020)

Highlights