The United States Supreme Court has held that the due process clause of the fourteenth amendment does not compel a state criminal trial court to conduct a hearing outside the jury's presence to determine the admissibility of identification evidence whenever a defendant contends that a witness's identification of him was arrived at improperly.
Watkins v. Sowders, 449 U.S. 341 (1981).
Constitutional Law - Fourteenth Amendment - Due Process Clause - Criminal Law - Identification Procedures,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol20/iss4/7