Where an investigation has begun to focus upon a particular suspect, whose request for counsel has been denied and who has not received a warning as to his right to remain silent, he has been deprived of his rights under the sixth amendment.
Escobedo v. State of Illinois, 84 Sup. Ct. 1758 (1964).
Frank A. Mysliwiec,
Constitutional Law - Right to Counsel,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol3/iss1/12