Section 10.22 Number of Photographs

• Library: Criminal Practice 2012 Supp

d. (§10.22) Number of Photographs

Use of a single photograph has been held not to be suggestive. See State v. McGrath, 603 S.W.2d 518 (Mo. 1980). The showing of a single photograph of a suspect to a witness when there is no improper comment or activity on the part of the police in showing the photograph does not result in impermissible suggestiveness. State v. Thomas, 705 S.W.2d 579, 582 (Mo. App. E.D. 1986), cited with approval in State v. Morant, 758 S.W.2d 110 (Mo. App. E.D. 1988); see also State v....