In re F.G.

In Watkins v. Sowders, 449 U.S. 341, 101 S.Ct. 654, 66 L.Ed.2d 549 (1981), the Supreme Court held that the Constitution does not require a per se rule compelling a judicial determination outside the presence of the jury of the admissibility of identification evidence in every case. The Court noted, however, that the prudence of such hearings had been emphasized by many decisions in the Courts of Appeals, id. at *306345 & n. 2, 101 S.Ct. at 657 & n. 2, and agreed that such a precedure “may often be advisable,” and even, “[i]n some circumstances[ ] not presented here, ... constitutionally…