In Stovall v. Denno (1967) 388 U.S. 293, the Supreme Court explained that under Linkletter v. Walker (1965), "the retroactivity of other constitutional rules of criminal procedure" "implicates (a) the purpose to be served by the new standards, (b) the extent of the reliance by law enforcement authorities on the old standards, and (c) the effect on the administration of justice of a retroactive application of the new standards." (Stovall, at pp. 296-297.) In Stovall, the court applied these criteria to determine the retroactivity of the rules announced in United States v. Wade (1967) 388 U.S. 218 and Gilbert v. California (1967) 388 U.S. 263 "requiring the exclusion of identification evidence which is tainted by exhibiting the accused to identifying witnesses before trial in the absence of his counsel." (Stovall, at p. 294.) The court concluded "the Wade and Gilbert rules should not be made retroactive" and further concluded "that, for these purposes, no distinction is justified between convictions now final, as in the instant case, and convictions at various stages of trial and direct review" because "the factors of reliance and burden on the administration of justice are entitled to such overriding significance as to make that distinction unsupportable." (Id. at pp. 300-301.) The court explained that the defendants in Wade and Gilbert had to be given the benefit of the new rules as "an unavoidable consequence of the necessity that constitutional adjudications not stand as mere dictum." (Stovall, at p. 301.) Recognizing that "inequity arguably results from according the benefit of a new rule to the parties in the case in which it is announced but not to other litigants similarly situated in the trial or appellate process who have raised the same issue," the court nonetheless "regarded the fact that the parties involved are chance beneficiaries as an insignificant cost for adherence to sound principles of decision-making." (Ibid.)