New Jersey v. Watson
Annotate this CaseIn January 2017, an individual wearing a baseball cap and gloves robbed a bank in North Brunswick, New Jersey. Bank surveillance footage captured the entire 57-second robbery. In November 2017, defendant was charged in three other robberies after his former girlfriend, “Joan,” identified him in a wanted photo from one of those robberies. After the office investigating the other robberies notified police about defendant, he became a suspect in the North Brunswick robbery as well. In September 2018, a detective showed the teller six photos, one at a time, and asked if he could identify the person who robbed the bank. The teller picked a photo of someone other than defendant and said at trial that he was 75-90 percent sure of the identification. At trial, the prosecutor asked the teller if he could identify the robber in court. The teller identified defendant, who was seated in between his lawyers at counsel table. The teller said he was “maybe like . . . 80 percent” sure. The prosecution did not provide advance notice of the in-court identification, and defense counsel did not object to it. During cross-examination, the teller revealed that he had met with the prosecutor prior to trial and that the prosecutor had “informed [him] that the individual who was accused of committing this robbery is in court seated at the defense table.” Joan also testified at trial. She was shown two still photos from the bank surveillance video and testified she was 100 percent positive that each depicted defendant. A police sergeant testified about the investigation, in which he was asked a series of questions while the video was played for the jury. The more open-ended questions invited and led to more open-ended narrative responses. A jury found defendant guilty of robbery. The Appellate Division affirmed his conviction. The New Jersey Supreme Court reversed, finding: (1) the inherently suggestive nature of first-time in-court identifications, conducted in front of a jury, risks depriving defendants of their due process rights; and (2) narration evidence, or "running commentary" on video evidence by someone who has merely studied a recording, violated defendant's right to confrontation. Judgment was reversed and the matter remanded for a new trial.
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