In United States v. Ash, the Court addressed the issue of whether post-indictment photographic displays required the presence of counsel and held:

a. A post-indictment photographic displays is not a “critical stage” of the prosecution and is not entitled to the presence of counsel.
b. A post-indictment photographic displays is a “critical stage” of the prosecution but is not entitled to the presence of counsel.
c. A post-indictment photographic displays is not a “critical stage” of the prosecution but is entitled to the presence of counsel.
d. A post-indictment photographic displays is a “critical stage” of the prosecution and is entitled to the presence of counsel.


a. A post-indictment photographic displays is not a “critical stage” of the prosecution and is not entitled to the presence of counsel.

Criminal Justice

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