California, United States of America
The following excerpt is from People v. Lawrence, 81 Cal.Rptr. 91 (Cal. App. 1969):
The reasonableness of the showing of photographs to an eye-witness for the purpose of possible identification of the perpetrator of the crime where an arrest has not yet been made has been recognized. (Simmons v. United States, 390 U.S. 377, 88 S.Ct. 967, 19 L.Ed.2d 1247.)
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