When an unrepresented defendant in police custody invokes his right to a lawyer, what is the effect of that right?

Our holding today represents but a logical extension of these principles. When an unrepresented individual who is being held in police custody invokes his right to the assistance of counsel as defendant did here, he is, in effect, "express(ing) his own view that he is not competent to deal with the authorities without legal advice" (Michigan v. Mosley, 423 U.S. 96, 110, n. 2, 96 S.Ct. 321, 329 n. 2, 46 L.Ed.2d 313, Supra (White, J., concurring)). Such an individual has no less need for the protections afforded by counsel than does an individual who, by happenstance, has previously secured the services of an attorney. Indeed, it makes little sense to say that a Represented defendant in custody cannot effectively waive his right to counsel in the absence of counsel, while at the same time holding that an individual who has not yet secured an attorney but who has nonetheless requested the services of one can subsequently make an informed and voluntary decision to waive his rights without the advice of a lawyer (see People v. Settles, 46 N.Y.2d 154, 164, 412 N.Y.S.2d 874, 282, 385 N.E.2d 419, 424, Supra ). Such a rule would impose an undue disadvantage upon those defendants who either are not affluent enough to have had regular dealings with an attorney prior to being arrested or have not had previous occasion to enjoy the services of appointed counsel in an unrelated criminal matter.