Use of defendant's incriminating statements, surreptitiously procured by government agents after indictment and in the absence of defendant's counsel, violates defendant's constitutional rights under the fifth and sixth amendments.
Massiah v. United States, 377 U.S. 201, 84. Sup. Ct. 1199 (1964).
Robert S. Barker,
Constitutional Law - Right to Counsel,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol3/iss1/11