United States, 512 U.S. 452, 459 (1994), the Court held that: "Although a suspect need not 'speak with the discrimination of an Oxford don,' he must articulate his desire to have counsel present sufficiently clearly that a reasonable police officer in the circumstances would understand the statement to be a request for an attorney." The Davis Court found that the defendant's remark, "Maybe I should talk to a lawyer," was not an unequivocal request for counsel. The Davis suspect made the "[m]aybe I should talk to a lawyer" remark before authorities filed any charges; therefore, the Sixth Amendment right to counsel had not yet attached. Id. at 456-57. Nor was there any indication in Davis that the suspect had retained an attorney. 23 See Bradford v. State, 927 S.W.2d 329, 335 (Ark. 1996) (<HOLDING>); Holloway v. State, 780 S.W.2d 787 (Tex. Crim.
holding that a mirandabased waiver did not apply to a represented defendant because he enjoyed the right to rely on counsel as a medium between himself and the state recognizing the right to counsel on appeal recognizing that the sixth amendment guarantees a defendant the right to counsel and the right to waive counsel holding had a right as a matter of law to rely on material misrepresentations of defense counsel that defendant would pay the policy limits holding that the state as well as the defendant has a right to rely on compliance with rule 16