State v. LujanAnnotate this Case
The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction of aggravated robbery on the ground that the legal framework established in State v. Ramirez, 817 P.2d 774 (Utah 1991), is no longer viable and reinstated the jury verdict on the alternative basis that any arguable error in admitting eyewitness identification evidence in this case was harmless.
Defendant was convicted based on eyewitness identification testimony and other evidence admitted at trial. The court of appeals reversed the conviction under the reliability factors set forth in Ramirez and on the ground that the improperly admitted eyewitness identifications were not harmless beyond a reasonable doubt. The court of appeals, however, also raised concerns about the viability of the standard set forth in Ramirez, indicating that the Ramirez framework must be revisited. The Supreme Court endorsed the need for revising and updating the factors set forth in Ramirez based on new developments in scientific and legal research regarding the reliability of eyewitness identification testimony. The Court then held (1) admissibility of eyewitness identification testimony is to be measured in the first instance by the rules of evidence; and (2) in this case, any error in admitting such evidence was harmless beyond a reasonable doubt.