Final answer:
The right to counsel in identification procedures only applies to lineups that occur after indictments, not before indictments or photo identification procedures.
Step-by-step explanation:
The right to counsel during identification procedures is recognized by the Supreme Court, but the extent of this right varies depending on the stage of the criminal process. In lineups that occur after indictments, the right to counsel has been recognized by the Supreme Court. However, this right does not automatically extend to lineups before indictments or photo identification procedures. The Supreme Court has not provided a clear answer regarding this issue, so the right to counsel in these situations is not well-established.