criminal, the level of certainty demonstrated by the witness at the confrontation, and the length of time between the crime and the confrontation." Neil v. Biggers, 409 U.S. 188, 199-200 (1972). No single factor is dispositive. See Kelly, 257 F.3d at 135. 66 EFTA00088868 C. Discussion There was nothing und

procedures that create "a very substantial likelihood of irreparable misidentification." Simmons v. United States, 390 U.S. 377, 384 (1968); accord Neil v. Biggers, 409 U.S. 188, 198 (1972); see also Manson v. Brat Waite, 432 U.S. 98, 106 n.9, 114 (1977). This principle applies both to show-ups, see, e.g., Sto