an unrepresented defendant's Sixth Amendment right to counsel during interrogation required no more for a valid waiver than did the Fifth Amendment doctrine
WAIVERS OF EVIDENTIARY PRIVILEGES BY LAWYERS Assisted by his or her lawyer, what Sixth Amendment rights may the accused assert at trial? Some of
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)