According to the case of United States v. Crews, a suspect who is identified through an illegal arrest and booking photo will not be admissible.

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In United States v. Crews, the Supreme Court held that the testimony of a witness who identified the defendant in court, based on seeing him during an illegal arrest, was not excluded by the Fourth Amendment because the witness's memory, not the illegal arrest, was the evidentiary source of the in-court identification.

According to the Case of United States V