Jarmone Tyric Adams v. State, 397 S.W.3d 760

Adams was convicted of aggravated robbery in Harris County, Texas, with a 35-year prison sentence following a jury trial.
Thompson identified Adams during a pre-trial video lineup and again at trial as the robber who used a firearm.
Thompson observed the robber for three to four minutes and described facial features, a teardrop tattoo, and clothing.
A suppression hearing addressed whether the pre-trial lineup was impermissibly suggestive; Costin helped create the lineup and Adams selected position two.
The trial court denied the motion to suppress and admitted the video lineup; Adams was convicted and sentenced.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the pretrial lineup was impermissibly suggestive	Adams argues lineup was impermissibly suggestive	State contends lineup followed department procedures	No reversible error; no substantial likelihood of misidentification established

Loserth v. State, 963 S.W.2d 770 (Tex. Crim. App. 1998) (two-step inquiry for pretrial identification admissibility)
Santos v. State, 116 S.W.3d 447 (Tex. App.—Houston [14th Dist.] 2003, pet. ref'd) (totality-of-circumstances test for misidentification)
Neil v. Biggers, 409 U.S. 188 (U.S. 1972) (factors for determining likelihood of misidentification)
Ibarra v. State, 11 S.W.3d 189 (Tex. Crim. App. 1999) (application of totality-of-circumstances approach)
Wiede v. State, 214 S.W.3d 17 (Tex. Crim. App. 2007) (deferential review of trial court's factual determinations)