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Cases hold that expert testimony on the reliability of eyewitness identification was properly refused on the basis that expert evidence on the reliability of eyewitness identification would invade the province of the jury. See Caldwell v. State, 267 Ark. 1053, 1059, 594 S.W.2d 24, 28-29 (App.1980); People v. Johnson, 112 Cal.Rptr. 834, 836-37, 38 Cal.App.3d 1, 6-7 (1974); James v. State, 232 Ga. 762, 763-64, 208 S.E.2d 850, 852-53 (1974); Pankey v. Commonwealth, 485 S.W.2d 513, 521-22 (Ky.App.1972).
Many courts consider eyewitness identification not a proper subject for expert testimony, See, e.g., State v. Valencia, 118 Ariz. 136, 138, 575 P.2d 335, 337 (App.1977); People v. Guzman, 121 Cal.Rptr. 69, 71-72, 47 Cal.App.3d 380, 385-86 (1975); Dyas v. United States, 376 A.2d 827, 831-32 (D.C.App.1977); Nelson v. State, 362 So.2d 1017, 1021 (Fla.App.1978); People v. Dixon, 87 Ill.App.3d 814, 818, 410 N.E.2d 252, 256 (1980); State v. Porraro, R.I., 404 A.2d 465, 471 (1979).
These views are rapidly falling by the wayside.
The law has long recognized the inherent danger in eyewitness testimony. See United States v. Wade, 388 U.S. 218, 87 S.Ct. 1926, 18 L.Ed.2d 1149 (1967). 'The vagaries of ...
