How have courts interpreted the Miranda rights of a suspect who waives their right to counsel?

As long as the suspect knowingly and intelligently waives these rights, the police are free to interrogate him. [Citation.]" (People v. Stitely (2005) 35 Cal.4th 514, 535 citing Miranda, supra, 384 U.S. at pp. 467-479.)

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.' [Citation.] '[A] reviewing court . . . must ask whether, in light of the circumstances, a reasonable officer would have understood a defendant's reference to an attorney to be an unequivocal and unambiguous request for counsel, without regard to the defendant's subjective ability or capacity to articulate his or her desire for counsel, and with no further requirement imposed upon the officers to ask clarifying questions of the defendant.' [Citations.]" (People v. Cunningham (2015) 61 Cal.4th 609, 646.) Waiver of the right to counsel is implied where a suspect indicates he understands his rights and subsequently gives statements to the police. (People v. Medina (1995) 11 Cal.4th 694, 752.) Statements obtained in violation of Miranda are inadmissible to prove guilt in a criminal case. (Ibid.)