The right to counsel attaches at an accusatorial proceeding even though not requested. The rule announced in Escobedo v. Illinois will not be applied retrospectively to cases finally adjudicated before Escobedo v. Illinois was decided.
Commonwealth v. Negri, 419 Pa. 117, 213 A.2d 670 (1965).
Joseph Pass Jr.,
Constitutional Law - Right to Counsel,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol4/iss2/8