United States v. Wade (1967) examined whether courtroom identifications of an accused at trial are to be excluded from evidence because the accused was exhibited to the witnesses before trial at a post-indictment lineup conducted for identification purposes without notice to and in the absence of the accused's appointed counsel. The Court ruled that defense counsel must be present for the evidence to be admissible. Kirby v. Illinois holds that counsel is not required at in-person suspect identifications that occur prior to arrest and the commencement of adversarial proceedings. Simmons v. United States (1968) holds that a photographic identification of a suspect by victims/witnesses in a bank robbery was not unnecessarily suggestive and conducive to misidentification. Neil v. Biggers (1972) holds that a lineup is not suggestive or conducive to misidentification when the witness had ample opportunity to view the offender during the crime, the witness' prior description of the offender was accurate, the witness is certain of the identification, and a significant amount of time has not elapsed between the crime and the confrontation. Dissenting opinions are included for some of the cases.