Darius Young v. United States, Nos. 12-CF-1860
& 12-CF-1861 (decided March 5, 2015).
Players: Associate Judges Fisher and Thompson, Senior Judge Belson. Opinion by Senior Judge Belson. PDS for Mr. Young. Trial judge: Ronna L. Beck.
Facts: Darius Young was arrested for a daytime
carjacking that was caught on surveillance video. The carjacker’s face was obscured in the
video, but his coat was visible. Police
found and arrested Mr. Young after tracking the signal of an iPhone left in the
stolen vehicle. Although Mr. Young was
wearing a coat similar to the one in the video, the stolen SUV was nowhere near
him and he did not have the iPhone. At
trial, the government relied on identification testimony from a social worker
who had worked extensively with Mr. Young and his family the previous year and
who had last seen Mr. Young after the date of the carjacking. The social worker testified that she
recognized the carjacker in the surveillance video as Mr. Young based on his
face, his stance, his gait, and his jacket.
Issue: Was it an abuse of discretion to admit lay
opinion testimony from a witness who knew Mr. Young that Mr. Young was the
person depicted in a surveillance video of a carjacking?
Holding: No.
The lay opinion identification testimony was admissible under Sanders v. United States, 809 A.2d 584
(D.C. 2002), because the social worker had had “extensive contact” with Mr.
Young, and because her superior ability to identify Mr. Young’s face, stance,
gait, and jacket was helpful to the jury.
MW.
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