Section 10.15 Right to Counsel at Photograph Displays

• Library: Criminal Practice 2012 Supp

1. (§10.15) Right to Counsel at Photograph Displays

The Supreme Court has held that the Sixth Amendment right to counsel does not apply at all to photographic displays even though the defendant is in custody and under indictment. See United States v. Ash, 413 U.S. 300 (1973); see also State v. Montgomery, 596 S.W.2d 735 (Mo. App. E.D. 1980). The Wade decision’s right to counsel does not attach in Missouri just because the defendant is represented by counsel on other charges. United States v. Wade, 388 U.S....