In a majority of states, a suspect is deemed to have invoked the Miranda right to counsel only if the suspect's request is clear and unequivocal. This doctrine is challenged as an insufficient protection of constitutional rights. It is argued that courts should treat even ambiguous and equivocal requests as per se effective innovations of the right to counsel.
In a Different Register: The Pragmatics of Powerlessness in Police Interrogation, 103 YALE L.J. 259