According to the Supreme Court,show-ups are:

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Show-ups are not always unconstitutional, but they are permissible if they do not result in a very substantial likelihood of misidentification. However, if the police could reasonably have set up a lineup instead, the show-up may be deemed unconstitutional. There is no requirement that defense counsel be present during a show-up, although a reliable identification may be more difficult to establish without counsel present.

According to the Supreme Court,show-Ups Are