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36 See Eda Katharine Tinto, Wavering on Waiver: Montejo v Louisiana and the Sixth Amendment Right to Counsel, 48 AM CRIM L REV 1335, 1370 (2011)

an unrepresented defendant's Sixth Amendment right to counsel during interrogation required no more for a valid waiver than did the Fifth Amendment doctrine

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[PDF] DISENTANGLING MIRANDA AND MASSIAH - Boston University

36 See Eda Katharine Tinto, Wavering on Waiver: Montejo v Louisiana and the Sixth Amendment Right to Counsel, 48 AM CRIM L REV 1335, 1370 (2011)

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[PDF] DISENTANGLING MIRANDA AND MASSIAH - Boston University