THE COURT HAS HELD THAT RELIABILITY OF THE IDENTIFICATION GOVERNS THE ADMISSIBILITY OF SUCH EVIDENCE. OVER THE YEARS, A SERIES OF CASES HAS RESULTED IN EXPANDED PRETRIAL IDENTIFICATION GUIDELINES ANY IN COURT IDENTIFICATION BY A WITNESS WHO HAS TAKEN PART IN A LINEUP IS ADMISSIBLE ONLY IF THE PROSECUTION CAN ESTABLISH BY CLEAR AND CONVINCING EVIDENCE THAT THE TESTIMONY IS IS BASED ON OBSERVATIONS INDEPENDENT OF THE LINEUP. THE SUSPECT HAS A RIGHT TO COUNSEL AT A PRETRIAL LINEUP, AND IF THIS RIGHT HAS BEEN DENIED, THE LINEUP IDENTIFICATION IS NOT ADMISSIBLE. SOME DEFENSE ATTORNEYS HAVE ARGUED THAT AN IDENTIFICATION PROCEDURE MAY BE SO SUGGESTIVE AND CONDUCIVE TO IRREPARABLE MISTAKEN IDENTIFICATION THAT THE ACCUSED IS DENIED DUE PROCESS OF LAW. THE SUPREME COURT HAS SUPPORTED SUCH ARGUMENTS ONLY WHEN THE PROCEDURE IS EXTREMELY, IMPERMISSIBLY SUGGESTIVE. IN OTHER OPINIONS, THE COURT HAS EXPRESSED A CONCERN FOR THE DETERRENCE OF QUESTIONABLE POLICE PRACTICES; IT FELT THAT POLICE MIGHT AVOID UNNECESSARILY SUGGESTIVE PROCEDURES FOR FEAR THAT A JUDGE AND JURY WOULD DISCOUNT THE WEIGHT GIVEN THE TESTIMONY AND DECREASE THE CHANCES OF A CONVICTION. SPECIFIC CASES AND DECISIONS APPROPRIATE TO THE ISSUE OF SUGGESTIVE IDENTIFICATION ARE EXAMINED. (VDA)