Supreme Court of Connecticut

State v. Johnson

July 29, 2014

Summary

The court held that an eyewitness identification resulting from suggestive conduct by a private actor does not automatically implicate the due process provisions of the Connecticut constitution. Due process is implicated only when, absent improper state action, the identification is so extremely unreliable that admitting it would deprive the defendant of a fair trial. Because the defendant's unpreserved challenge was evidentiary rather than constitutional, the court declined to review it and affirmed the conviction.