Tatum v. Commissioner of Correction

Summary

The court held that the constitutional rule governing prescreening of first-time, in-court eyewitness identifications applies retroactively in state collateral proceedings when scientific developments prompted the rule, the rule materially improves conviction accuracy, and the petitioner previously raised the underlying claim. The court declined to apply retroactively the evidentiary rule concerning expert testimony on eyewitness identification. It reversed the dismissal of the petitioner's due process and actual innocence-related counts and remanded for a trial applying the constitutional rule retroactively.