Can a defendant be denied due process by admitting to a pretrial identification that is "so impermissibly suggestive as to give rise to irreparable misidentification"?

A defendant may be denied due process by admission of a pretrial photographic identification that is "so impermissibly suggestive as to give rise to a very substantial likelihood of irreparable misidentification." United States v. Hanigan, 681 F.2d 1127, 1133 (9th Cir.1982) (quoting Simmons v. United States, 390 U.S. 377, 384 (1968)), cert. denied, 459 U.S. 1203 (1983). "Identification procedures that emphasize a single individual's photograph may be unduly suggestive." Id. (citing Simmons, 390 U.S. at 383).