Calvin Byrd, Defendant Below, Appellant v. State of Delaware, Plaintiff Below, Appellee

Summary

The court held that the two-step due-process reliability test for suggestive pretrial identifications does not apply to an initial in-court identification that was not preceded by an impermissibly suggestive pretrial confrontation. Any suggestiveness in such an identification is addressed through cross-examination, argument, and the trial court's discretion over the manner of identification. Because the officer's identification was subject to those safeguards and the trial judge did not abuse his discretion in admitting it, the convictions were affirmed.