State v. Hoskins
State v. Hoskins, 199 Ariz. 127,35, 14 P.3d 997, 1008-09 (2000) involved the use of a show-up identification of an individual suspected of kidnapping an eighteen-year-old girl.
In Hoskins, the state argued that the defendant had "no constitutional right to a physical line-up" and that one-man show-ups were permissible under state law. Id.33.
At the time the show-up was conducted, the victim was still missing.
The court observed that the show-up was justified under the circumstances, but it went on to conclude, based on its examination of the Biggers factors, that the identification was properly admitted based on its reliability. Id.31, 34-35.