559 U.S. 98, 104, 106, 110, 130 S.Ct. 1213, 175 L.Ed.2d 1045 (2010), clarified that Edwards was a “judicially crafted rule,” and that the presumption from Edwards—the suspect’s waiver of Miranda rights after the invocation of the right to counsel is involuntary—is inapplicable when a suspect has experienced a fourteen-day break in custody. Based on these two temporal standards, it is clear that the police’s ability to re-interrogate a suspect following his or her invocation of the right to counsel is noticeably more restricted than with an invocation of the right to remain silent. By contrast, both the right to counsel and the right to remain silent require an unambiguous invocation by the suspect. See Berghuis v. Thompkins, 560 U.S. 370, 130 S.Ct. 2250, 2260, 176 L.Ed.2d 1098 (2010) (<HOLDING>); Davis, 512 U.S. at 459, 114 S.Ct. 2350
holding that during police interrogation right to remain silent must be invoked unambiguously holding that a suspect who wants to invoke his or her right to remain silent must do so unambiguously holding that a suspect must unambiguously request counsel holding that police may continue questioning a suspect until he unambiguously invokes his right to remain silent holding that an accused must unambiguously invoke the right to remain silent