Oregon v. LawsonAnnotate this Case
In two criminal cases consolidated for purposes of opinion, each defendant's conviction was based, for the most part, on eyewitness identification evidence. In "Oregon v. Lawson," the Court of Appeals concluded that, despite the state's use of unduly suggestive pretrial identification procedures, under the test first articulated by the Supreme Court in "Oregon v. Classen," (590 P2d 1198 (1979)), the victim's identification of defendant Lawson had been reliable enough to allow the jury to consider it in its deliberations. In "Oregon v. James," (again relying on "Classen") the Court of Appeals similarly concluded that, although the witnesses had been subject to an unduly suggestive police procedure in the course of identifying defendant James, those identifications had nevertheless been sufficiently reliable, and were therefore admissible at trial. The Supreme Court allowed review in each of these cases to determine whether the Classen test was consistent with the current scientific research and understanding of eyewitness identification. In light of the scientific research, the Court revised the test set out in Classen and adopted several additional procedures, based generally on applicable provisions of the Oregon Evidence Code (OEC), for determining the admissibility of eyewitness identification evidence.