The Supreme Court of the United States has held that an explicit statement of waiver is not necessary to support a finding that a defendant waived the right to remain silent or the right to counsel guaranteed by
Miranda v. Arizona. North Carolina v. Butler, 441 U.S. 369 (1979).
Anthony M. Bittner,
Constitutional Law - Sixth Amendment - Waiver of the Right to Counsel,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol18/iss4/11