112 L.Ed.2d 170 (1990). 6 . See United States v. Judge, 864 F.2d 1144, 1145 (5th Cir.1989) (observing that "no manual can reasonably be expected to spell out in detail the correct action in light of the almost infinite array of objects an agent may encounter”), cert. denied, 495 U.S. 918, 110 S.Ct. 1946, 109 L.Ed.2d 309 (1990). 7 . See Brief for Andrews at 22-23 ("The ruling [denying Andrews’ motion to suppress] holds only that the statements were voluntarily given; there is no ruling as to whether Andrews’ Miranda waiver occurred ‘knowingly’ or 'intelligently.' ... In this, the trial court erred.”); Reply Brief for Andrews at 16 (referring to "deficiency in the district court’s findings"). 8 . See Edwards v. Arizona, 451 U.S. 477, 483-84, 101 S.Ct. 1880, 1884, 68 L.Ed.2d 378 (1981) (<HOLDING>). 9 . See also Sims v. Georgia, 385 U.S. 538,
holding fundamental error occurred because the trial court failed to inquire thoroughly whether the juvenile understood her right to counsel and had the capacity to intelligently choose to waive counsel and failed to obtain the required verified written waiver holding that waiver of counsel during pcr review requires a judicial inquiry into whether defendant knowingly and intelligently waived his right to counsel holding that waiver of counsel may be valid absent an inquiry by the court where the surrounding facts and circumstances including the defendants background and conduct demonstrate that he actually understood his right to counsel and the difficulties of pro se representation and knowingly and intelligently waived his right internal quotation marks omitted holding that lower courts misunderstood the requirement for finding a valid waiver of the right to counsel where neither the trial court nor the arizona supreme court undertook to focus on whether edwards understood his right to counsel and intelligently and knowingly relinquished it holding that in order for a waiver of counsel to be valid the trial court must ensure that the defendants waiver of his right to counsel is done knowingly and intelligently so that the record establishes that the defendants choice is made with eyes open