to be a request for an attorney.” Id. at 459, 114 S.Ct. 2350. It is not enough that the suspect might be invoking the right to counsel; rather, the suspect must do so unambiguously. Id. (citations omitted). When a suspect makes an ambiguous statement, police officers need not cease an interrogation, id. at 459-60, 114 S.Ct. 2350 (citation omitted), or ask clarifying questions, id. at 461-62. Peters’s statement, “I’d like to get to that part now,” by itself goes nowhere toward invoking the right to counsel. However, Peters claims that under the circumstances its meaning is clear. While we agree that Peters’s words should be viewed in the context in which they were spoken, as Davis requires, id. at 459, 114 S.Ct. 2350, case law in this area is strict. E.g., id. at 462, 114 S.Ct. 2350 (<HOLDING>); United States v. Brown, 287 F.3d 965, 972-73
holding maybe i should talk to a lawyer to be ambiguous holding suspects contradictory answers on miranda waiver form that he would answer questions without an attorney and that he wanted to talk to a lawyer to be ambiguous holding statements i just dont think that i should say anything and i need somebody that i can talk to to be ambiguous rather than assertion of right to remain silent holding i might want to talk to an attorney to be ambiguous holding do you think i need a lawyer to be ambiguous