greeing with the position taken by Justice Sotomayor and relying on common law evidentiary principles, the Massachusetts Supreme Judicial Court has ruled that state trial judges may conduct pretrial admissibility hearings and exclude unreliable identification evidence even if the police are not responsible for the suggestive procedures (Commonwealth v. Johnson, 2016). Most of the Supreme Court decisions we have considered thus far have concerned corporeal identification procedures. For various reasons, including the difficult logistical challenges in assembling a multi-person lineup composed of individuals who resemble the described suspect, and the suggestiveness inherent in conducting one-person show-ups, the police instead frequently ask witnesses to view photographs or computer-generated composites when they attempt to identify crime suspects. As discussed earlier, the witness in Manson v. Brathwaite, Officer Glover, viewed a single photograph and thereafter confirmed that the subject (Brathwaite) was the man who had sold him heroin. Presenting a witness with the photo of only one person to determine if a suspect can be identified is clearly far more suggestive than providing photographs of several different people. However, even a photo array with pictures of multiple individuals can be suggestive. For example, the police might have displayed the photos in a way that made the true suspect stand out, or inadvertently suggested through a gesture or a verbal cue which phot