The United States Supreme Court has held that a lineup conducted prior to indictment is not a critical stage of the prosecution and therefore the sixth amendment right to counsel is not applicable.
Kirby v. Illinois, 406 U.S. 682 (1972).
Warren D. Ferry,
Constitutional Law - Criminal Procedure - Right to Counsel at Lineup,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol11/iss3/7