California, United States of America
The following excerpt is from People v. Green, 3 Cal.App.3d 240, 83 Cal.Rptr. 491 (Cal. App. 1969):
(1) That in July of 1967--after the decision in United States v. Wade (1967) 388 U.S. 218, 87 S.Ct. 1926, 18 L.Ed.2d 1149, he was placed in a lineup without the presence of counsel and that there is no showing that he had waived his right to counsel;
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