In Linkletter v. Walker, 381 U.S. 618 (1965), the Supreme Court first attempted to establish some standards for determining the retroactivity of new rules. The issue was whether Mapp v. Ohio, 367 U.S. 643 (1961), which made the exclusionary rule for evidence applicable to the states, applied retroactively. 381 U.S. at 636-40. To answer the question, the Court adopted a three-part test that considered: (a) the purpose to be served by the new rule; (b) the extent of reliance on the prior rule; (c) the effect retroactive application of the new rule would have on the administration of justice. Using that standard, the Court held that Mapp would only apply to trials commencing after that case was decided. 381 U.S. at 636-40. Two years later, in Stovall v. Denno, 388 U.S. 293 (1967), the Court applied the Linkletter factors and held that the rule requiring exclusion of identification evidence tainted by exhibiting the accused for identifying witnesses before trial in the absence of counsel also did not apply retroactively. 388 U.S. at 300. Stovall also held that the new rule would not apply even to cases pending on direct review. Id. at 300-01.