In re Richard W

In In re Richard W. (1979) 91 Cal.App.3d 960, the trial court rejected a contention that exhibition of the appellant in a police car in handcuffs with police officers nearly was impermissibly suggestive. The minor, apprehended at the scene, was identified minutes after apprehension. The court, while noting single person showups should not be used absent compelling circumstances, observed in-field identifications in close proximity in time and place to the scene of the crime are favored in the law.