The United States Supreme Court in Neil v. Biggers, 409 U.S. 188 (1972), articulated five factors to consider in determining reliability of an out-of-court visual identification. By analogy, to determine whether a voice identification is admissible, the court must consider: (1) the witness' opportunity to hear the accused at the time of the crime; (2) the witness' degree of attention; (3) the accuracy of the witness' prior description of the suspect's voice; (4) the level of certainty demonstrated by the witness at the time of the voice identification; (5) the length of time between the crime and the identification. See 409 U.S. at 199-200. The United States Supreme Court enunciated five factors relevant to a reliability assessment of an out-of-court identification: the opportunity of the witness to view the criminal at the time of the crime, the witness' degree of attention, the accuracy of the witness' prior description of the criminal, the level of certainty demonstrated by the witness at the confrontation, and the length of time between the crime and the confrontation. Id. at 199-200; In Neil v. Biggers, the United States Supreme Court held that an identification derived from unnecessarily suggestive procedures, which has a likelihood of leading to a misidentification, violates a defendant's right to due process. Accordingly, a simply "suggestive identification procedure" will not result in a suppression of the identification unless the procedure impacts the reliability of the identification itself. Id. The United States Supreme Court and the Sixth Circuit Court of Appeals have long recognized the danger inherent in eyewitness identifications resulting from show-ups, even if these courts have found, under the totality of the circumstance, the identification was reliable. See Stovall v. Denno (1967), 388 U.S. 293, 87 S.Ct. 1967, 18 L. Ed. 2d 1199; Gregory v. Louisville (C.A.6, 2006), 444 F.3d 725. The Court found that, under the totality of the circumstances, the show-up identification in that case was reliable "even though the confrontation procedure was suggestive." (Id. at p. 199.) The court continued: "As indicated by our cases, the factors to be considered in evaluating the likelihood of misidentification include the opportunity of the witness to view the criminal at the time of the crime, the witness' degree of attention, the accuracy of the witness' prior description of the criminal, the level of certainty demonstrated by the witness at the confrontation, and the length of time between the crime and the confrontation." (Id. at pp. 199-200.) The Court stated that "with the deletion of 'irreparable' it serves equally well as a standard for the admissibility of testimony concerning the out-of-court identification itself." The Court went on further to hold that unnecessary suggestiveness alone does not require exclusion of evidence. Id. at 198-99. In that instance, the "central" question is "whether under the 'totality of the circumstances' the identification was reliable even though the confrontation procedure was suggestive." Id. at 199.