The U.S. Supreme Court has held that a showup following arrest but before the initiation of adversarial criminal proceedings is a critical stage of criminal prosecution, and thus the right to counsel applies.

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The U.S. Supreme Court has not explicitly held that a showup following arrest but before the initiation of adversarial criminal proceedings is a critical stage of criminal prosecution. However, some lower courts have extended the right to counsel to this stage in certain circumstances.

The US Supreme Court Has Held That a Showup Following Arrest