In United States v. Ash, the Supreme Court held that:
a. Law enforcement violated the Sixth Amendment by conducting a photo identification procedure because the procedure took place after the defendant's indictment and defense counsel was not present.
b. Law enforcement did not violate the Sixth Amendment by conducting a photo identification procedure because the in-court identification was based on an independent source.
c. Law enforcement did not violate the Sixth Amendment by conducting a photo identification procedure because the defendant had no right to be present for the photographic lineup.
d. Law enforcement violated the Sixth Amendment by conducting a photo identification procedure because the procedure was highly suggestive and likely to result in misidentification.