In United States v. Crews (1980) 445 U.S. 463, the court considered when an in-court identification of the defendant should be suppressed as the fruit of his unlawful arrest. In Crews, photographs of the defendant were taken after he was illegally arrested. Those photographs were later shown to a robbery victim in a photographic array, and she identified the defendant as the perpetrator of the crime. At trial, the victim again identified the defendant as her assailant. Evidence obtained through violation of the Fourth Amendment prohibition of illegal searches and seizures is inadmissible at trial. (Crews, supra, 445 U.S. at p. 470.) This exclusion extends to any fruits of the illegal search or seizure, including observations made or statements overheard during an illegal detention. (Ibid.) In determining whether the victim's in-court identification of the defendant was the product of an unlawful detention, the Court stated: "A victim's in-court identification of the accused has three distinct elements. First, the victim is present at trial to testify as to what transpired between her and the offender, and to identify the defendant as the culprit. Second, the victim possesses knowledge of and the ability to reconstruct the prior criminal occurrence and to identify the defendant from her observations of him at the time of the crime. And third, the defendant is also physically present in the courtroom, so that the victim can observe him and compare his appearance to that of the offender." (Crews, supra, 445 U.S. at p. 471.) Because none of these elements was the result of exploitation of the Fourth Amendment violation, the court concluded the in-court identification of the defendant was not a fruit of the illegal arrest. (Crews, supra, 445 U.S. at p. 471.) As to the first element, the victim's presence in court was not the result of any illegal conduct; she reported the crime, gave the police a full description of the suspect, and cooperated in their investigation before any police misconduct occurred. (Id. at pp. 471-472.) As to the second element, the victim constructed a mental image of her assailant from her observations at the time of the robbery, compared this image with defendant, and positively identified him as the robber. The illegal detention did not affect her ability to give accurate identification testimony. (Id. at p. 472.) As to the third element, an illegal arrest or detention does not bar a subsequent prosecution; a defendant is not a suppressible fruit of the unlawful detention and "the illegality of his detention cannot deprive the Government of the opportunity to prove his guilt through the introduction of evidence wholly untainted by the police misconduct." (Id. at p. 474.)