State v. Lawson

In State v. Lawson, 25 Kan. App. 2d at 140, a robbery victim called 911 immediately after the robbery and provided a description of the robber as a black male in his thirties, about 5 ' 11" tall, weighing 180 pounds, and wearing a green and blue plaid shirt. Shortly thereafter, police spotted a suspect matching the victim's description near the area of the robbery. After arresting the suspect, the police returned him to the scene of the robbery for identification by the victim. The Court determined that the one-person show-up identification was unnecessarily suggestive but upheld the admission of the identification based on the Neil v. Biggers factors. 25 Kan. App. 2d at 142-44.