United States v. Watson, No. 14-1334 (2d Cir. 2015)
Annotate this CaseThe Government appealed the district court's grant of defendant's motion to suppress evidence. Law enforcement officers were pursuing a robbery suspect when they mistakenly identified defendant as the suspect. A frisk of defendant produced a gun and 27 bags of crack cocaine. The district court found that the suspect and defendant have different facial features, skin tones, heights, ages, and so forth. These material differences would have been apparent to any reasonable officer, especially on who had had previous contact with the suspect, and would have been further corroborated by defendant's production of his identification. The court concluded that the district court's effective legal conclusion - that a reasonable officer, once he had had a chance to view defendant close up, could not have reasonably believed he was the suspect - is fully supported by the factual findings and is not clearly erroneous. Accordingly, the court affirmed the judgment.
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