State of Utah, Plaintiff and Appellee v. Livio Alphonso Ramirez, Defendant and Appellant

Summary

The court held that the eyewitness identification was constitutionally admissible under Utah's due process clause after applying an empirically informed reliability analysis. It nevertheless vacated the aggravated-robbery conviction because the trial court failed to make the factual findings and legal determination necessary to decide whether Ramirez was unlawfully seized and whether the identification was tainted by that seizure. The court remanded for a new trial rather than allowing a post hoc ruling on admissibility.