Which statement about voice-identification procedures is accurate under due process analysis?

• A. A voice-identification procedure is unduly suggestive if it is likely to result in misidentification, and the totality of circumstances governs.
• B. The 6th Amendment requires counsel to be present for all voice identifications regardless of stage.
• C. Totality of the circumstances is irrelevant to voice identifications.
• D. Voice identifications are never subject to due process concerns.

Answer: (A)