Zavion Alahad v. State of Florida

Summary

The court held that abuse-of-discretion review governs trial court rulings on motions to suppress out-of-court identifications, including the application of law to the historical facts. Applying that standard, it concluded that the trial court reasonably admitted the eyewitness identification because the show-up was not unnecessarily suggestive. The court approved the district court's decision, clarified inconsistent precedent, and disapproved contrary use of de novo review.