State v. Reed, 247 P.3d 1074

Reed convicted of aggravated robbery, aggravated assault, and obstruction of official duty in Kansas after eyewitness identification at trial.
Eyewitness identification occurred when Orabuena, shortly after the crime, viewed Reed in a patrol car and identified him.
District court denied suppression of the identification despite finding it unnecessarily suggestive.
Prosecution presented in-court identification and the physical evidence (wallet, $10, $1 bills) linking Reed to the crime.
Two days after the robbery, a small silver gun was found near Reed’s flight path.
Reed challenges suppression ruling, unanimity instruction, and Allen-type instruction before deliberations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the eyewitness identification properly admitted?	Reed: identification procedure unnecessarily suggestive.	State: Corbett allows reliability review after suggestiveness.	Yes, identification admissible after reliability review.
Was a unanimity instruction required for aggravated robbery?	Becker requires unanimity for multiple acts.	State: alternative means case, no unanimity needed.	Unanimity not required; substantial evidence supports alternative means.
Was the Allen-type instruction error reversible?	Instruction erroneous and prejudicial.	Salts error not reversible since not outcome-determinative.	Not reversible error; instruction not likely to change outcome.

State v. Corbett, 281 Kan. 294, 130 P.3d 1179 (2006) (two-step test for eyewitness ID admissibility; reliability under totality of circumstances)
State v. Hunt, 275 Kan. 811, 69 P.3d 571 (2003) (original Hunt factors for reliability analysis)
State v. Becker, 290 Kan. 842, 235 P.3d 424 (2010) (unanimity in alternative means vs. multiple acts cases)
State v. Salts, 288 Kan. 263, 200 P.3d 464 (2009) (Allen-type instruction error not reversible when trial timing pre-deliberations)
State v. Alires, 246 Kan. 635, 792 P.2d 1019 (1990) (time-critical show-up identifications; exigent circumstances)