It is stated in the case U.S. v. Wade, 388 U.S. 218 (1967), that a police lineup or other "face-to-face" confrontation after the accused has been formally charged with a crime is considered a "critical stage of the proceedings;" therefore, the accused has the right to have counsel present. However, there is no right to counsel at police lineups or identification procedures prior to the time the suspect is formally charged with the crime, according to Kirby v. Illinois, 406 U.S. 682 (1972). In the case, Foster v. California, 394 U.S. 440 (1969), it was found that lineups which are so suggestive as to make the resulting identifications virtually inevitable violate a suspect's constitutional right to due process. And, in the case U.S. v. Dionisio, 410 U.S. 1 (1973), the Court determined that any person may be required against his or her will to appear before a grand jury. Also stated in that case was that suspects may be required by the police to give voice exemplars.