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Maria was charged with purse snatching. After charges were filed and counsel was appointed, detectives showed the victim a six-photo array without notifying Maria's lawyer. All six photos showed women of similar age and complexion, but Maria's photo was brighter than the others and showed her wearing a red scarf. The victim had previously told police that the thief wore a red scarf. The victim picked Maria and said she was "pretty sure."
The next day, a detective texted the victim a single photo of Maria and wrote, "This is the woman we arrested; please confirm before court." The victim replied, "Yes, that is definitely her." Separately, before speaking to detectives, the victim had searched social media on her own and saved a photo from Maria's public page because she thought Maria looked like the thief.
Maria moves to suppress the photo-array identification, the text-message identification, and any trial identification. Analyze the Sixth Amendment, due process, police-arranged suggestiveness, private-identification, and reliability issues.