State of New Jersey, Plaintiff-Respondent v. James Madison, Defendant-Appellant

Summary

The Supreme Court of New Jersey held that the out‑of‑court photographic identification procedures used against James Madison were impermissibly suggestive because the defendant’s photograph was shown repeatedly, and therefore remanded the case for a taint hearing to determine whether the identifications had an independent source, placing the burden on the State to prove such a source by clear and convincing evidence.