What is the effect of a police officer's lack of knowledge that a suspect had previously invoked his right to counsel?

Once the suspect invokes the right to counsel, the officer's subjective state of mind remains irrelevant to the question whether the suspect subsequently waived the right to counsel. As the court determined in Arizona v. Roberson, supra, 486 U.S. 675, 108 S.Ct. 2093, 100 L.Ed.2d 704, the interrogating officer's lack of knowledge that the suspect previously invoked his right to counsel is irrelevant to the question whether the suspect knowingly and voluntarily waived the right to counsel, because the relevant inquiry is the suspect's state of mind. (Id. at p. 687, 108 S.Ct. at p. 2101.) If the officer's good faith in commencing the interrogation is irrelevant because the focus is on the suspect's state of mind, it appears that the officer's bad faith would be equally irrelevant.