Young v. Alaska

June 18, 2016 by Justia

Defendant Aaron Young was accused of involvement in a shooting and convicted at trial, in part on the strength of three eyewitness identifications. He challenged the admissibility of two of the identifications on due process grounds, but the superior court ruled them admissible. Defendant also requested an eyewitness-specific jury instruction, which the superior court refused. Furthermore, defendant argued that he was entitled to a mistrial because of an alleged discovery violation by the State that he learned of mid-trial. The superior court denied his motion, finding that the State had not violated the disclosure rules and alternatively that the defendant had not suffered any prejudice. The defendant was convicted, and the court of appeals affirmed his conviction. On petition to the Alaska Supreme Court, defendant argued not only that his conviction should have been reversed based on the current law on the admissibility of eyewitness identifications, but also that Alaska’s due process clause required the adoption of a new test. He also argued that the superior court erred in failing to give his requested jury instruction and in failing to grant him a mistrial. The Supreme Court held that the superior court erred under the law as it currently existed when it held one of the eyewitness identifications sufficiently reliable to be admitted at trial, but that it did not err in admitting the other. The Court also held that the superior court erred in refusing to give an eyewitness-specific jury instruction but did not err in denying a mistrial. Because the errors were harmless, the Court affirmed defendant’s conviction. In light of the issues raised by this appeal, the Court concluded that the current test for the admissibility of eyewitness identification evidence does not adequately protect the right to due process under the Alaska Constitution. The Court therefore identified factors that courts should consider in future cases when deciding whether to admit eyewitness identification evidence. View "Young v. Alaska" on Justia Law