In Kirby v. Illinois the Court held that a defendant does not have the right to counsel at a showup conducted following an arrest but before his or her ____________.

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In Kirby v. Illinois, the Supreme Court held that the Sixth Amendment right to counsel does not attach until formal judicial proceedings are initiated, such as at arraignment, indictment, or preliminary hearing. Therefore, a defendant does not have the right to counsel at a showup (a police identification procedure) conducted before these formal proceedings, which includes all the options listed: arraignment, preliminary hearing, and indictment.

In Kirby V