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Mistaken eyewitness identification is one of the leading causes of wrongful convictions in America. Memory is not a video recording — it is fragile, malleable, and easily distorted by stress, brief exposure, cross-racial identification, and, above all, suggestive police procedures. When the State's case rests on someone pointing across a courtroom, challenging the reliability of that identification can be the whole ballgame.

If you or a loved one has been identified as a suspect in Houston, Harris County, or Galveston, Brian Foley and Luis Baez — former prosecutors — can help.

Why Eyewitnesses Get It Wrong

FactorWhy it undermines reliability
Stress & weapon focusHigh stress and a visible weapon narrow attention away from the face
Brief or poor exposureShort glimpses, distance, and poor lighting degrade memory
Cross-racial identificationPeople are measurably less accurate identifying other races
Suggestive proceduresLineups and showups can steer a witness to the police's suspect
Post-event informationLater comments and repeated viewings contaminate the memory

How We Challenge an Identification

  • Motion to suppress. We move to exclude identifications produced by unnecessarily suggestive procedures.
  • Attacking the procedure. We examine whether the agency followed Texas's required written lineup policies — blind administration, proper fillers, and cautionary instructions.
  • Expert testimony. We present qualified experts on the science of memory and misidentification.
  • Cross-examination. We probe the conditions of the observation, the witness's certainty over time, and any contaminating influences.
  • Alibi and corroboration. We develop alibi and highlight the absence of physical evidence tying you to the offense.
Certainty is not accuracy

A confident witness is not necessarily a correct one — and confidence often grows after the fact, through feedback and repetition. Juries need to understand that, and part of our job is making sure they do.

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Why HCDA

Brian Foley is Board Certified in Criminal Law, and both he and Luis Baez are former prosecutors who understand how identifications are obtained — and how often they are wrong. If you believe you have been misidentified in Houston, Harris County, or Galveston, contact Houston Criminal Defense Attorneys PLLC for a free, confidential consultation. Call or text (713) 703-1718.

Frequently Asked Questions


How reliable is eyewitness identification?
Far less reliable than most people assume. Decades of research, and hundreds of DNA exonerations, show that mistaken eyewitness identification is one of the leading causes of wrongful convictions. Memory is not a recording — it can be shaped by stress, weapon focus, brief exposure, cross-racial identification, and suggestive police procedures.
Can a mistaken identification be challenged in court?
Yes. We can move to suppress an identification that resulted from unnecessarily suggestive procedures, cross-examine the witness on the conditions of the observation and the identification process, and present expert testimony on the science of memory and misidentification. We also scrutinize whether proper procedures — like blind administration and lineup fillers — were followed.
What makes a lineup or photo array suggestive?
Suggestive procedures include a lineup where the suspect stands out, an officer who signals or confirms the choice, showing the witness only one person ('showups'), repeated exposure to the same face, and failing to warn the witness the suspect may not be present. Texas law requires agencies to have written identification policies to reduce these risks.
Does Texas have rules for police lineups?
Yes. Texas law requires law enforcement agencies to adopt detailed written policies for photo and live lineups, incorporating best practices such as blind or blinded administration, proper fillers, and cautionary instructions. When an agency fails to follow its own policy or the statute, that failure can be used to challenge the identification.
What is the defense if I've been misidentified?
Misidentification — that the witness has the wrong person — is a complete defense. We build it by attacking the reliability of the identification, presenting alibi and other evidence, using expert testimony on memory, and highlighting the absence of corroborating proof. Where the ID was the core of the State's case, undermining it can end the case.

Speak With a Houston Criminal Defense Attorney Today


Free, confidential consultation with Board Certified criminal defense attorneys and former prosecutors.

(713) 703-1718