What is the effect of the Phipps rule on identification of a suspect?

The identification in the instant case, as in Phipps, was made swiftly and without hesitation. Finally the identification in the instant case took place only eleven days after the robbery clearly not the lengthy delay which creates the danger that "the initial image will have dimmed and that the second image will play a significant role." Id. at 915. See, e. g., United States ex rel. Rutherford v. Deegan, 406 F.2d 217 (2d Cir. 1969) (10 days). If anything, this case is, on the whole, a stronger one for the application of the Phipps rule than was the Phipps case itself.