v. Louisiana, 444 U.S. 469, 100 S.Ct. 652, 62 L.Ed.2d 622 (1980). To be valid, such a waiver must also have been voluntary. Colorado v. Connelly, 479 U.S. 157, 167, 107 S.Ct. 515, 522, 93 L.Ed.2d 473 (1986); Moran v. Burbine, 475 U.S. 412, 421, 106 S.Ct. 1135, 1141, 89 L.Ed.2d 410 (1986). Our waiver analysis does not address this issue because Valdez does not claim that his waiver was involuntary. 16 . Moran v. Burbine, 475 U.S. at 421, 106 S.Ct. at 1141. 17 . The United States Court of Appeals for the Ninth Circuit has recognized that "language dif-Acuities may impair the ability of a person in custody to waive [their Miranda rights] in a free and aware manner.” U.S. v. Heredia-Fernandez, 756 F.2d 1412, 1415 (9th Cir.1985). See also U.S. v. Short, 790 F.2d 464, 469 (6th Cir.1986) (<HOLDING>). But see U.S. v. Bautista-Avila, 6 F.3d 1360,
holding that police failure to inform the accused of his attorneys attempts to contact him and misstatements to the attorney as to whether the accused was at the police station did not violate the accuseds due process rights holding that accuseds waiver of miranda rights was unknowing and unintelligent where accused spoke broken english had a deficient understanding of the english language and knew nothing about the american criminal justice system holding that jury trial in civil cases is not so fundamental to the american system of justice as to be required of state courts by due process holding that where a suspect was given miranda warnings and then immediately spoke without police prompting that statement was voluntary and therefore admissible recognizing that the accuseds right to be represented by counsel is a fundamental component of our criminal justice system