In what circumstances have courts found that a witness's identification was unreliable for a reason other than the suggestive pretrial procedures?

We know of no similar case in which the trial court concluded the identification evidence was unreliable for a reason other than the suggestive pretrial procedures. Appellant, however, has not shown us why our approach to the issue here should be different from those in which the trial court finds the identification was based on the witness's independent recollection. In either type of case, the crucial finding is that the identification did not result from the photographic procedures. If the trial court has made findings of fact supported by substantial evidence, we are bound to accept those [17 Cal.App.4th 823] findings. (People v. Cheatham (1971) 21 Cal.App.3d 675, 679, 98 Cal.Rptr. 670.)