How have the courts treated photo lineups in criminal cases?

Defendants argue that the photo lineups were unduly suggestive. There are various ways for a lineup procedure to be suggestive. For instance, in People v. Carlos (2006) 138 Cal.App.4th 907, 910-912, a six-photo lineup was impermissibly suggestive because the suspect's name and an identifying number were printed beneath the suspect's picture, but nothing was printed beneath any of the other pictures. In People v. Sandoval (1977) 70 Cal.App.3d 73, 85 (involving a live lineup), the problem was in remarks officers made: They told the witness in advance that the suspect was the person who would be seen passing through a certain hallway. Here, however, defendants have not shown any similar defects, either in the photo sets themselves or in the circumstances under which the witnesses were shown them.