Marcus, R. v

Marcus, R. v

The use of unmasked images in the video identification procedure was a deliberate and unfair violation of Code D, rendering the convictions on counts dependent on that evidence unsafe. The judge should have excluded the evidence. The convictions on counts 8 and 10, supported by independent evidence, remain safe and are not contaminated by the flawed procedure.

Parties
Respondent: Regina; Appellant: Ruel Marcus
Jurisdiction
England and Wales
Judgment Date
23 November 2004
Procedural Posture
Criminal Appeal / Judgment on Appeal Against Conviction
Outcome
Appeal allowed in part
Legal Topics
Robbery, False Imprisonment, Identification Evidence, Police and Criminal Evidence Act, Code D Compliance

Case Brief

Summary, issues, holding and outcome

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Parties

Regina

Respondent

Ruel Marcus

Appellant

Procedural Posture

Criminal Appeal / Judgment on Appeal Against Conviction

  1. 1 Whether the video identification procedure violated Code D of the Police and Criminal Evidence Act 1984
  2. 2 Whether the convictions based on the impugned identification evidence were unsafe
  3. 3 Whether procedural defects contaminated other convictions

Ratio Decidendi

The use of unmasked images in the video identification procedure was a deliberate and unfair violation of Code D, rendering the convictions on counts dependent on that evidence unsafe. The judge should have excluded the evidence. The convictions on counts 8 and 10, supported by independent evidence, remain safe and are not contaminated by the flawed procedure.

Court Disposition

Appeal allowed in part

Orders

  • Convictions on counts 4, 12, 14, 15, 16, and 17 quashed
  • Convictions on counts 8 and 10 upheld