California, United States of America
The following excerpt is from The People v. Gordon, C056183, No. 04F06813 (Cal. App. 2010):
there is no meaningful distinction between the Sixth Amendment rights addressed in Massiah v. United States (1964) 377 U.S. 201 [12 L.Ed.2d 246] (Massiah) and the Fifth Amendment rights discussed in Rhode Jsland v. Jnnis (1980) 446 U.S. 291, 297 [64 L.Ed.2d 297].
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