The following excerpt is from Wilson v. Gomez, 105 F.3d 668 (9th Cir. 1996):
"[A]fter a knowing and voluntary waiver of the Miranda rights, law enforcement officers may continue questioning until and unless the suspect clearly requests an attorney." Davis v. United States, 114 S.Ct. 2350, 2356 (1994). A suspect "must articulate his desire to have counsel present sufficiently clearly that a reasonable police officer in the circumstances would understand the statement to be a request for an attorney." id. at 2355.
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