In United States v. Ash, 413 U.S. 300 (1973), the Supreme Court acknowledged that the right to counsel had been extended to events occurring prior to trial, but determined that the expansion was limited to those events where the accused was "confronted, just as at trial, by the procedural system, or by his expert adversary, or by both." 413 U.S. at 310. The Ash Court reasoned that in such "trial-like" confrontations, the function of the lawyer remains essentially the same as his function at trial--to act as a spokesman for, or advisor to, the accused. See id. at 312. According to the Court, the traditional test to emerge from these previous right to counsel cases focuses on whether the accused requires "aid in coping with legal problems or assistance in meeting his adversary." Id. at 313. On this basis, the Ash Court held that the Sixth Amendment does not require counsel's presence at photographic displays. See id. at 321.