Biggers factors (Kentucky) · Go Syfert
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Biggers factors in Kentucky

9 Kentucky opinions name it 2 courts 1995–2020 0 in the last five years

The cases below were cited by Kentucky courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Neil v. Biggersgreen
scotus · 1972 · cited in 3 Kentucky opinions naming this issue, 2003–2020
2 sentences

2020Consider the five Biggers factors set out by the Supreme Court of the United States, as follows: [T]he factors to be considered in evaluating the likelihood of misidentification include [1] the opportunity of the witness to view the criminal at the time of the crime, [2] the witness’ degree of attention, [3] the accuracy of the witness’ prior description of the criminal, [4] the level of certainty demonstrated by the witness at the confrontation, and [5] the length of time between the crime and the confrontation. 409 U.S. at 199-200 , 93 S. Ct. at 382 (bracketed numerals added).

2020Consider the five Biggers factors set out by the Supreme Court of the United States, as follows: [T]he factors to be considered in evaluating the likelihood of misidentification include [1] the opportunity of the witness to view the criminal at the time of the crime, [2] the witness’ degree of attention, [3] the accuracy of the witness’ prior description of the criminal, [4] the level of certainty demonstrated by the witness at the confrontation, and [5] the length of time between the crime and the confrontation. 409 U.S. at 199-200 , 93 S. Ct. at 382 (bracketed numerals added).

23
Commonwealth v. Parkergreen
ky · 2013 · cited in 2 Kentucky opinions naming this issue, 2017–2017
2 sentences

2017"The Biggers factors are: (1) the opportunity of the witness to view the defendant; (2) the witness’s degree of attention; (3) the accuracy of any prior descriptions; (4) the level of the witness’s certainty when confronting the defendant; and (5) the time between the crime and the confrontation of the defendant.” Commonwealth v. Parker, 409 S.W.3d 350, 353 (Ky. 2013) (citing Savage v. Commonwealth, 920 S.W.2d 512, 513-14 (Ky. 1995)). 5 .

2017"The Biggers factors are: (1) the opportunity of the witness to view the defendant; (2) the witness’s degree of attention; (3) the accuracy of any prior descriptions; (4) the level of the witness’s certainty when confronting the defendant; and (5) the time between the crime and the confrontation of the defendant.” Commonwealth v. Parker, 409 S.W.3d 350, 353 (Ky. 2013) (citing Savage v. Commonwealth, 920 S.W.2d 512, 513-14 (Ky. 1995)). 5 .

22
Wilson v. Commonwealthgreen
ky · 1985 · cited in 2 Kentucky opinions naming this issue, 2017–2017
2 sentences

2017In Wilson v. Commonwealth, 695 S.W.2d 854, 857 (Ky. 1985), this Court summarized the requirements of the Biggers test.

2017In Wilson v. Commonwealth, 695 S.W.2d 854, 857 (Ky. 1985), this Court summarized the requirements of the Biggers test.

22
United States v. Russell E. Hillgreen
ca6 · 1992 · cited in 2 Kentucky opinions naming this issue, 2017–2017
2 sentences

2017See, e.g., Lee v. Foster, 750 F.3d 687 (7th Cir. 2014) (applying the two-part test, but ruling that the particular in-court proceedings were not unnecessarily suggestive), United States v. Hill, 967 F.2d 226, 232 (6th Cir. 1992) (“All of the concerns that underlie the Biggers analysis, ... are no less applicable when the identification takes place for the first time at trial.”); but cf. United States v. Domina, 784 F.2d 1361, 1368 (9th Cir. 1986) (Acknowledging that in-court identifications are inherently suggestive, but asserting that different considerations apply when the initial identifica

2017See, e.g., Lee v. Foster, 750 F.3d 687 (7th Cir. 2014) (applying the two-part test, but ruling that the particular in-court proceedings were not unnecessarily suggestive), United States v. Hill, 967 F.2d 226, 232 (6th Cir. 1992) (“All of the concerns that underlie the Biggers analysis, ... are no less applicable when the identification takes place for the first time at trial.”); but cf. United States v. Domina, 784 F.2d 1361, 1368 (9th Cir. 1986) (Acknowledging that in-court identifications are inherently suggestive, but asserting that different considerations apply when the initial identifica

22
Keith Lee v. Brian Fostergreen
ca7 · 2014 · cited in 2 Kentucky opinions naming this issue, 2017–2017
2 sentences

2017See, e.g., Lee v. Foster, 750 F.3d 687 (7th Cir. 2014) (applying the two-part test, but ruling that the particular in-court proceedings were not unnecessarily suggestive), United States v. Hill, 967 F.2d 226, 232 (6th Cir. 1992) (“All of the concerns that underlie the Biggers analysis, ... are no less applicable when the identification takes place for the first time at trial.”); but cf. United States v. Domina, 784 F.2d 1361, 1368 (9th Cir. 1986) (Acknowledging that in-court identifications are inherently suggestive, but asserting that different considerations apply when the initial identifica

2017See, e.g., Lee v. Foster, 750 F.3d 687 (7th Cir. 2014) (applying the two-part test, but ruling that the particular in-court proceedings were not unnecessarily suggestive), United States v. Hill, 967 F.2d 226, 232 (6th Cir. 1992) (“All of the concerns that underlie the Biggers analysis, ... are no less applicable when the identification takes place for the first time at trial.”); but cf. United States v. Domina, 784 F.2d 1361, 1368 (9th Cir. 1986) (Acknowledging that in-court identifications are inherently suggestive, but asserting that different considerations apply when the initial identifica

22
Savage v. Commonwealthgreen
ky · 1995 · cited in 3 Kentucky opinions naming this issue, 2003–2017
2 sentences

2017"The Biggers factors are: (1) the opportunity of the witness to view the defendant; (2) the witness’s degree of attention; (3) the accuracy of any prior descriptions; (4) the level of the witness’s certainty when confronting the defendant; and (5) the time between the crime and the confrontation of the defendant.” Commonwealth v. Parker, 409 S.W.3d 350, 353 (Ky. 2013) (citing Savage v. Commonwealth, 920 S.W.2d 512, 513-14 (Ky. 1995)). 5 .

2017"The Biggers factors are: (1) the opportunity of the witness to view the defendant; (2) the witness’s degree of attention; (3) the accuracy of any prior descriptions; (4) the level of the witness’s certainty when confronting the defendant; and (5) the time between the crime and the confrontation of the defendant.” Commonwealth v. Parker, 409 S.W.3d 350, 353 (Ky. 2013) (citing Savage v. Commonwealth, 920 S.W.2d 512, 513-14 (Ky. 1995)). 5 .

13
Commonwealth v. Craytongreen
mass · 2014 · cited in 1 Kentucky opinions naming this issue, 2017–2017
2 sentences

2017Fairley also cites this Court to Commonwealth v. Crayton, 470 Mass. 228 , 21 N.E.3d 157, 169 (2014), in which Massachusetts adopted a new rule mandating that ‘‘[wjhere an eyewitness has not participated before trial in an identification procedure, we shall treat the in-court identification as an in-court showup, and shall admit it in evidence only where there is ‘good reason’ for its admission.” 6 .

2017Fairley also cites this Court to Commonwealth v. Crayton, 470 Mass. 228 , 21 N.E.3d 157, 169 (2014), in which Massachusetts adopted a new rule mandating that ‘‘[wjhere an eyewitness has not participated before trial in an identification procedure, we shall treat the in-court identification as an in-court showup, and shall admit it in evidence only where there is ‘good reason’ for its admission.” 6 .

11
Jones v. Commonwealthgreen
kyctapp · 1977 · cited in 1 Kentucky opinions naming this issue, 1995–1995
1 sentence

1995See Jones v. Commonwealth, Ky.App., 556 S.W.2d 918, 921 (1977).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
United States v. Gary Stephen Dominagreen
ca9 · 1986 · cited in 1 Kentucky opinions naming this issue, 2017–2017
2 sentences

2017See, e.g., Lee v. Foster, 750 F.3d 687 (7th Cir. 2014) (applying the two-part test, but ruling that the particular in-court proceedings were not unnecessarily suggestive), United States v. Hill, 967 F.2d 226, 232 (6th Cir. 1992) (“All of the concerns that underlie the Biggers analysis, ... are no less applicable when the identification takes place for the first time at trial.”); but cf. United States v. Domina, 784 F.2d 1361, 1368 (9th Cir. 1986) (Acknowledging that in-court identifications are inherently suggestive, but asserting that different considerations apply when the initial identifica

2017See, e.g., Lee v. Foster, 750 F.3d 687 (7th Cir. 2014) (applying the two-part test, but ruling that the particular in-court proceedings were not unnecessarily suggestive), United States v. Hill, 967 F.2d 226, 232 (6th Cir. 1992) (“All of the concerns that underlie the Biggers analysis, ... are no less applicable when the identification takes place for the first time at trial.”); but cf. United States v. Domina, 784 F.2d 1361, 1368 (9th Cir. 1986) (Acknowledging that in-court identifications are inherently suggestive, but asserting that different considerations apply when the initial identifica

11

Also cited on this issue (2)

CaseCitedYears
August Kennaugh v. David H. Miller, Superintendent of Eastern Correctional Facility green
ca2 · 2002
2 sentences

2017In support of this argument, Fairley relies on Kennaugh v. 4 "The Biggers factors are: (1) the opportunity of the witness to view the defendant; (2) the witness's degree of attention; (3) the accuracy of any prior descriptions; (4) the level of the witness's certainty when confronting the qefendant; arid (5) the time between the crime and the confrontation of the defendant." Commonwealth v. Parker, 409 S.W.3d 350, 353 (Ky. 2013) (citing Savage v. Commonwealth, 920.S.W.2d 512, 513-14 (Ky. 1995)). 8 Miller, 289 F.3d 36 (2nd Cir. 2002).

2017In support of this argument, Fairley relies on Kennaugh v. 4 "The Biggers factors are: (1) the opportunity of the witness to view the defendant; (2) the witness's degree of attention; (3) the accuracy of any prior descriptions; (4) the level of the witness's certainty when confronting the qefendant; arid (5) the time between the crime and the confrontation of the defendant." Commonwealth v. Parker, 409 S.W.3d 350, 353 (Ky. 2013) (citing Savage v. Commonwealth, 920.S.W.2d 512, 513-14 (Ky. 1995)). 8 Miller, 289 F.3d 36 (2nd Cir. 2002).

22017–2017
King v. Commonwealth green
ky · 2004
1 sentence

2015Id.; King, 142 S.W.3d at 649 ; Savage v. Commonwealth, 920 S.W.2d 512 (Ky.1995).

12015–2015

Statutes the citing opinions construe

KY § Ky. Rev. Stat. § 514.110 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 99 (2005–2026) TX 81 (1982–2025) MS 43 (1982–2020) TN 20 (1994–2022) AZ 17 (1987–2020) OH 15 (1999–2025) VA 12 (1997–2025) CT 11 (2005–2025) WA 11 (2001–2025) KY 9 (1995–2020) MD 9 (1998–2019) KS 9 (1992–2012) NH 7 (1982–2016) AL 6 (1984–2014) FL 5 (1983–2018) IA 4 (2018–2023) WI 4 (1997–2021) WV 4 (1981–1989) SC 4 (2003–2022) MI 4 (2020–2023) NY 3 (1979–2010) DC 3 (2021–2025) ND 3 (1988–2007) RI 2 (2018–2021) DE 2 (1975–2023) UT 2 (2004–2015) HI 2 (1981–2019) PA 2 (2019–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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