Arron N. Young, Petitioner v. State of Alaska, Respondent

Summary

The court affirmed Young’s convictions despite concluding that one eyewitness identification was improperly admitted and that the trial court should have given an eyewitness-specific jury instruction. It held that the admission error and instructional error were harmless, that a second in-court identification was admissible because it was not procured through state action, and that the discovery violation did not warrant a mistrial because the State rebutted Young’s specific claim of prejudice. Prospectively, the court replaced the existing reliability test for eyewitness identification evidence with a broader framework based on system and estimator variables.