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A young man robbed a woman in a women's restroom at the Washington National Monument. During the robbery, the woman had a good opportunity to see the young man. The woman immediately reported the robbery and described the young man who robbed her. Three days later, a young man (Crain) was improperly and illegally detained. Photographs were taken of the young man and a photographic display (array) was shown to the woman. She immediately identified Crain as the man who robbed her at gunpoint. In a lineup, the woman again identified Crain as the robber. At Crain's trial for armed robbery, the woman appeared as a witness and identified the defendant as the robber. Crain was convicted, and he appealed arguing that the in-court-identification was the "fruit of the poisonous tree" and should not be used as evidence.
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