Oregon v. Haugen

Defendant Shawn Haugen was convicted of one count of third-degree assault, based mainly on the victim’s eyewitness identification of him. Before his trial, defendant moved to exclude the eyewitness identification. Applying the test for admissibility of eyewitness testimony set out in “Oregon v. Classen,” (590 P2d 1198 (1979)), the trial court ruled that the victim’s eyewitness identification was admissible. While the case was pending on appeal, the Oregon Supreme Court announced its decision in “Oregon v. Lawson/James,” (291 P3d 673 (2012)), in which the Court substantially revised the Classen test for determining the admissibility of eyewitness testimony. In the Court of Appeals, defendant argued that the identification procedures used in this case raised serious questions about the reliability of the identification under “Lawson/James,” and, therefore, that the Court of Appeals should have remanded the case to the trial court for a new hearing and trial, with the trial court utilizing the “Lawson/James” test. The Court of Appeals disagreed, concluding that, even under “Lawson/James,” the trial court correctly denied defendant’s motion to suppress. The Supreme Court allowed review and, reversed the decision of the Court of Appeals. View "Oregon v. Haugen" on Justia Law