California, United States of America
The following excerpt is from People v. Jelks, B280897 (Cal. App. 2018):
"A claim that an identification procedure was unduly suggestive raises a mixed question of law and fact to which we apply a standard of independent review, although we review the determination of historical facts regarding the procedure under a deferential standard." (People v. Clark (2016) 63 Cal.4th 522, 556-557.)
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