In Brewer v. Williams, the Supreme Court reaffirmed the notion that the government may not use unlawful means to secure the conviction of a criminal, but the Court failed to define with any certainty what is and what is not interrogation. The question of what satisfies the strict waiver standard is also unanswered.

I. Introduction

II. The Facts of the Case

III. The Issues … A. The Right to Counsel during Interrogation … B. Waiver

IV. Conclusion