Since 1964, courts have beenrequired to exclude confessions that were deliberately elicited from suspects after the Sixth Amendment right to counsel had attached (usually, by indictment or first court appearance) and had been asserted (as when the suspect retained, requested, or was appointed an attorney on the case). (Massiah v. U.S.)rnIn 1986, the Supreme Court said that police could not obtain a valid waiver of the Sixth Amendment right to counsel for an admissible statement on the charged case following attachment and assertion of the right. (Michigan v. Jackson) But just two years later, the court went halfway to overruling Jackson (Patterson v. Illinois), and has now completely reversed it.
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