Watkins v. Sowders (1980)
- Docket
- 79-5949
- Decided
- 1980-01-01
Summary
Question: Is a state criminal trial court constitutionally compelled to conduct a hearing outside the presence of the jury whenever a defendant contends that a witness’ identification was improper? Conclusion: No. Justice Potter Stewart delivered the opinion of the 7-2 majority. The Court held that the Due Process Clause of the Fourteenth Amendment does not require a state criminal court to conduct a hearing out of the jury’s presence whenever a defendant contends that a witness’ identification was improper. The reliability of the identification evidence determines its admissibility, which can be evaluated under the trial judge’s jury instructions and the Due Process Clause is satisfied when the defendant is given the opportunity to cross-examine the witness to test the reliability of the identification. The Court held that while it is advisable for there to be a judicial determination of admissibility of identification evidence, it is not required.