In Perry v. New Hampshire, U.S. 132 S. Ct. 716, 723, 181 L. Ed. 2d 694 (2012), the Court observed that the "primary aim of excluding identification evidence obtained under unnecessarily suggestive circumstances . . . is to deter law enforcement use of improper lineups, showups, and photo arrays in the first place." Id. at , 132 S. Ct. at 726. Thus, the "deterrence rationale" does not apply when "the police have engaged in no improper conduct." Id. The Court held that "when no improper law enforcement activity is involved, . . . it suffices to test reliability through the rights and opportunities generally designed for that purpose," such as "vigorous cross-examination" at trial. Id. at , 132 S. Ct. at 721. There, the Court declined to impose a prescreening requirement for certain in-court identification evidence precisely because it trusted the "safeguards built into our adversary system" to test the reliability of such evidence at trial. Perry, U.S. at , 132 S. Ct. at 728. In so reasoning, the Court identified several protections providing due process to a defendant who challenges the reliability of in-court identifications occurring after suggestive pretrial identification procedures: among them, the Sixth Amendment right to confront the eyewitness; the defendant's concomitant right to effective cross-examination of the eyewitness; and, important here, the use of "eyewitness-specific jury instructions, which . . . warn the jury to take care in appraising identification evidence." Id. at , 132 S. Ct. at 728-29.