The Pennsylvania Supreme Court held that once a suspect invokes his right to counsel, and he is allowed to consult with counsel, he may not be subsequently interrogated without his counsel present.
Commonwealth v Santiago, 528 Pa 516, 599 A2d 200 (1991).
Constitutional Law - Fifth Amendment - Right to Counsel - Custodial Interrogation,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol31/iss2/13