arrest and suppressed evidence where she knew that police arrested edgar sixteen year old african american boy was without probable cause or a warrant while he's walking down the street in his own southside neighborhood and there did not match the description of the people that took the complaint job real browns cell phone what were the what were the descriptions there were two officers agave descriptions of the people they're looking specific description or not i don't think that's a very specific description because it actually contains no physical characteristic of the person themselves well but weren't there other descriptions that they were young  one of them had on a black jumpsuit but more specifically a purple jacket with a black stripe then another individual in black or dark clothing and then another individual a white shirt and a do rag but but also that they were during the show all right let's let's get back to the probable cause and move to really  descriptions that actually meet the descriptions given the stock biased individualized suspicion and there was nothing that specifically related to my client that would have justified a terrorist stop he was not wearing those clothes that were described is that what we're looking at this we're looking at we're going to take now an individual person and then we have to look at what they have for that person is that what you're suggesting absolutely  on it and they see that person now i know you don't think that's a very specific scriptures but there was more like a set young male black certain age i thought time it was not too long after the events the location was close proximity to where the events occur itself are you basically saying the police should ignore the personal purple she added with the stripes when i mean that's probably a specific if you're going to get as far as a piece of clothing a few points actually again that was briefly detaining them is to rule in or rule out but we don't look at this equation now with deciding whether your client was wearing that we're looking at this as to whether one of the individuals just my argument here today is that counsels entire strategy at trial was to challenge your dedication evidence and specifically the complaints inability to identify my client from the shero but she still fit the profile most of the boss rest and suppress evidence that was the strongest course of action for counsel at that time success and that motion would have excluded the most damaging evidence a case  in the shop so there is no justification for search incident to arrest and isn't there a dispute about whether your client was that the state is disputing that yes but at trial the officer the only officer who was present with the after police showed him a picture of my client and said we found your family on this person do you recognize him and he said he was sure of him after they showed him a officer i said that's one of the kids that slapped me now so he did testify and direct that he made an identification on cross he says ok so it wasn't until you were back at least station and the police actually showed you a photo of my client and you and told you that the phone was found on the person that you identified him after rock yes now although that pulled up his picture and showed me at the station so i mean it there's certainly room for discussion but to say he never write down if i can is not really an accurate description of the did not the complaint did not identify my client her failure chief file a motion allowed the introduction of a post arrest identification it allowed the introduction of the complaint cell phone the scription the only fact that is consistent in my client in the information police had was that my client is an african american teenager well this is the record here we look back now look at the entire record direct and then there's some wavering on cross and then you have this later testimony from the young man who was victimized basically explaining that they all changed clothes and there's nothing to contradict that there's no evidence to contradict that the purple jacket with the stripe was definitely there that is in my opinion rather descriptive i know you don't think it is but a purple check it with stripes is more than we ever get so after the fact you have this person saying i was absolutely positive we was when i saw the fog but you have this description before and you have a tentative identification and case law indicates that tentative identification can support where we have basically under your eyes interpretation which i disagree with i don't think there is an investigation that the trial judge did not have an opportunity to make credibility determination problem we're looking at something some of the cases this is better left to a post conviction titian than right this court trying to now put it all together and piece it together to decide whether or not right in people the little  he does not have firsthand knowledge of the complaints stated in the car  because there was no basis for probable cause there was no individualized suspicion to justify terry stop and no reasonable suspicion at a very quickly and during that show up probable cause arose and that was based on the the city that they were close to where the battery and robbery had just occurred it's based on them wearing the same clothing that they were teenagers and it's based on the identification the victim here identified one one teenager who carried the purple jacket and said i he was there but he wasn't one of the guys that they hit me or took my phone but he was there to he was there i recognize him he's one of the kids that that's like me and then they asked and then when asked about responded on direct as your honor stated were you able to identify anyone he said yes he said yes again and he made it very clear to the court that he was able to identify the respondent on cross examination it got a little confusing because trial counsel probably out of there was she was supposed to do she poked holes in his identification she knew there was on the responded and no one else now for purposes of the theory stuff how would you respond to there because the police work looking for one person they were looking for several people in fact two people  slapped this young man one slapped him first left side his face right side then the other did it on the other side of his face and then the phone was subsequently taken but the fact he made or is that this was not an incident involving an individual it was an incident well the multiple individuals with multiple descriptions so how do you respond to the police stopping and detaining what appeared to be a group based on an advanced it involved more than one person the commonsense practical approach here which this court has said should be applied is that the office would stop the group of teenagers if they just heard over the radio were involved in a robbery and a battery they were forty years and teenagers involved except for teenagers they're wearing the clothing that was described they were teenagers and they were in the vicinity that the police have today exactly what they were and how was it close in time drives in over the show up and he's in the car with the victim asking him if you can to identify any of these teenagers are detective watts standing twenty feet away this is and he's not in another area it's twenty feet away and he's told there's a positive identification so there is something is transpiring here between his police officers whether it was tentative whether it was i think that's him in his chest this just me was i think that's him who was there i think that is there any doubt that was there any kind of a pat down before the fellow you know there was not your honor there was a terry stop there was a proper show up and probable cause came about during the show up when the victim identified three out of four of these teenagers and he said what he said that guy was there but he didn't do anything right wearing his jacket that i was there and he slapped me and that and i think i recognized him there and that's the responding and at that point office main guys he was talking to me the whole time at the park so at this point in time at the trial you know he's just want to have put this whole thing together maybe he wasn't certain of the world that responded played in that moment of the show up but it was certainly sure of it because he was able to describe a physical rose detective was testified at that moment he he did search incident to arrest and they continued their investigation at the at the police department and not all the individuals were ultimately arrested so that was absolutely reasonable for the police officer to conduct that show up and to arrest based on the probable cause and for that reason there was absolutely no basis for a motion to quash arrest and the trial counsel knew this and she was more than reasonable in her representation of responded her cross examination was quite effective she got this young victim a little bit confused little bit backtracking and poked holes and vacation which was clearly her strategy texas confirmed that the police need individualized reasonable suspicion they must articulate specific facts related to the person who's challenging the violation of their rights to justify cherry stuff the fact that my client was rocking near some people who are your blue match a very general nonspecific description stopped near ninety fifth and rested about a mile away but they also called the pair veterans park which is eight miles from the scene of the stop so i don't think you can say with any certainty this happened close to the time of the offense where near the location of the fence of how far away was built the stock was a ninety fifth the western death the state argued that the offense occurred at a park near ninety something california that distance is about a he was not a benefit and there's at least be an opportunity for credibility determination where the completely unimpeached credible police officer the only person who was present to hear what the complaint had to say admitting he did not benefit my client counsel should have filed a motion