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Donald Anderson appealed his bank robbery conviction, arguing that evidence of a pre-arrest lineup identification should not have been allowed. The Court affirmed the conviction, finding that Anderson was already lawfully in custody for another crime so an arrest was not required. The lineup was also not unfairly conducted, with counsel present and disguises used. Witnesses testified they identified the number four person in the lineup as the robber, and an officer then identified that person as Anderson. T

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