right to counsel requires an objective inquiry. Id. at 458-59, 114 S.Ct. 2350. The suspect must, “at a minimum, [give] some statement that can reasonably be construed to be an expression of a desire for the assistance of an attorney.” Id. at 459, 114 S.Ct. 2350 (internal quotation marks omitted). A statement is ambiguous when a “reasonable officer in light of the circumstances would have understood only that the suspect might be invoking the right to counsel.” Id. (first emphasis added). The United States Supreme Court has never declared its right to counsel principles applicable to invoking the right to silence, and under AEDPA that precedent was not “clearly established” when the California Court of Appeal rendered its decision. See Bui v. DiPaolo, 170 F.3d 232, 239 (1st Cir.1999) (<HOLDING>). Indeed, in prior cases, we have declined to
recognizing that davis was concerned only with the right to counsel and not the right to remain silent holding that the rationale of davis applies equally to a defendant who has waived his rights and later ambiguously invokes the right to remain silent during  interrogation recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel recognizing the right to counsel on appeal holding that an accused must unambiguously invoke the right to remain silent