Pretrial identification
1. 6th amendment: right to counsel: right to counsel at any post-charge lineup or show-up; no right to counsel at photo identifications or when police take physical evidence
2. Due process standard: pretrial i.d. cannot be unnecessarily suggestive or create a substantial likelihood of misidentification (e.g., ? is only black person in line up)
3. Remedy: an unconstitutional pretrial i.d. will be excluded at trial unless the witness has an independent source for the i.d. (such as chance to observe at the scene of the crime); admissibility should be determined at suppression hearing