The following excerpt is from U.S. v. Sanchez, 603 F.2d 381 (2nd Cir. 1979):
Finally, although there was a period of over fifteen months between the crime and the in-court identification, which is a "somewhat negative factor," United States v. Williams, supra, 596 F.2d at 49, we do not feel that this is so long an intervening period of time as to render the identification unreliable. Cf. Id. (in-court identification by lay witness was sufficiently reliable to warrant its admission into evidence despite time lapse of two years and eight months between crime and in-court confrontation).
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