at 223. This “stop and clarify” rule ensures that suspects are aware of their right to have counsel present during a custodial interrogation so that any subsequent waiver of this right is knowing and intelligent. Our case law illustrates that proper recitation of the suspect’s constitutional rights is key to proper clarification. See, e.g., Hannon, 636 N.W.2d at 805 n. 2 (stating in dicta that an officer’s statement that defendant’s “side of [the] story [would] never be known” if he requested counsel was not a proper clarification because it “implied that [the defendant] had to make a choice between either talking to an attorney and never having his side of the story known or continuing to talk with officers” (alterations in original) (emphasis added)); Pilcher, 472 N.W.2d at 332 (<HOLDING>); State v. Doughty, 472 N.W.2d 299, 303
recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel holding that juveniles may waive right to counsel only upon advice of counsel recognizing that the sixth amendment guarantees a defendant the right to counsel and the right to waive counsel holding that the defendant validly waived right to conflictfree representation where the defendant knew a conflict existed its effect on his defense and his right to have other counsel appointed holding that the defendant validly waived his right to counsel when after equivocally invoking the right while simultaneously expressing a desire to tell his side of the story police explained that they could speak only if the defendant first agreed to waive counsel