Commonwealth of Kentucky v. William Parker

Summary

The Kentucky Supreme Court reversed the Court of Appeals and held that the trial court did not err in denying Parker’s motion to suppress Martin’s out‑of‑court identification of Masengale. The Court found that, despite the suggestive nature of the show‑up, the totality‑of‑the‑circumstances factors—viewing opportunity, attention, prior description, certainty, and elapsed time—were sufficiently satisfied, allowing the identification to be admitted. The Court affirmed the trial court’s findings without requiring Martin’s testimony. Justice Cunningham, in a concurring opinion, argued that the Court should first have addressed Parker’s standing to challenge the identification.