The Ohio Court of Appeals has upheld a trial court's decision regarding the use of a photo array in the case against Michael Price. The ruling, issued on June 30, 2026, affects Price's convictions for robbery and grand theft of a motor vehicle. This decision is important as it addresses the legal standards surrounding eyewitness identification and the use of social media in criminal investigations.
Michael Price faced multiple charges in two separate cases consolidated under the docket number L-25-00181. The first case involved a theft from a Lowe’s store, while the second case stemmed from an incident where Price allegedly assaulted a woman and stole her vehicle. The court's ruling primarily focused on Price's appeal concerning the denial of his motion to suppress a photo array used for identification by the victim.
In the first case, CR23-02141, Price was indicted for stealing $1,164 worth of merchandise from a Lowe’s store on June 14, 2023. After entering a guilty plea in May 2024, he was placed in an intervention program. However, he later violated the terms of that program, leading to a guilty verdict for theft. The trial court sentenced him to 12 months in prison, which was to run concurrently with any sentence from the second case.
The second case, CR24-02610, arose from an incident on October 27, 2024, when the victim, identified as A.S., met Price at a nightclub. After realizing she was too intoxicated to drive, she stopped her vehicle. Price then assaulted her and stole her car. A.S. contacted the Toledo Police Department shortly after the incident to report the crime.
Detective James Tucker responded to A.S.’s call and conducted an initial interview. Later, A.S. provided Tucker with Price's Facebook profile, which led to the creation of a photo array that included Price's booking photo. A.S. identified Price from the array, but Price argued that the identification process was unduly suggestive due to the prior exposure to his Facebook profile.
During the suppression hearing, Detective Tucker testified about the steps he took to prepare the photo array. He explained that he used a booking photo of Price and selected other photos of individuals with similar characteristics to ensure fairness. The trial court ultimately denied Price's motion to suppress the identification, stating, "The Court does not find that providing a Facebook profile, which included a photograph of the suspect, made her later identification of Defendant unduly suggestive."
On appeal, Price maintained that the photo array was tainted by A.S.’s prior identification of him through social media. However, the court ruled that the identification process did not violate due process rights. The judges noted that the photo array included individuals with similar features and that the victim's identification was independent of the police procedure.
“An identification must be both unduly suggestive and unreliable to be suppressed,” the court stated. The judges found that the identification was reliable despite the victim's prior knowledge of Price from Facebook. Therefore, the court affirmed the trial court's decision.
This ruling has implications for future cases involving eyewitness identification, particularly in the context of social media. It clarifies that the use of a photo array is not automatically compromised by prior exposure to a suspect's image on social media, as long as the identification process is conducted properly.
The decision also emphasizes the importance of ensuring that photo arrays are constructed fairly, with attention to the characteristics of the individuals included. This ruling may influence how law enforcement agencies approach identification procedures in the future, particularly as social media continues to play a role in criminal investigations.
Looking ahead, Price has the option to appeal this ruling to the Ohio Supreme Court. However, details on whether he plans to pursue further legal action were not available in the court filing. The outcome of this case could set a precedent for how courts handle similar identification issues in the future.