592 (1976), rev’g United States v. Fink, 502 F.2d 1 (5th Cir. 1974). In Geders the Court held that a criminal defendant’s Sixth Amendment right to counsel was denied by a district court order barring consultation between the defendant and his attorney during an overnight recess that fell between the direct examination and the cross-examination of the defendant. The Court, however, expressly noted that it was not considering an order that merely barred a defendant from consulting his attorney during a brief routine recess during the trial day. Geders, supra, 425 U.S. at 89 n. 2, 96 S.Ct. at 1336 n. 2. Nevertheless, a number of Circuits have either adopted or expressed approval of the extension of Geders to short, mid-day recesses. United States v. Bryant, 545 F.2d 1035 (6th Cir. 1976) (<HOLDING>); United States v. Allen, 542 F.2d 630 (4th
holding an order directing defendant not to converse with anyone during an hour lunch break violative of the sixth amendment right to counsel holding that a criminal defendant has a sixth amendment right to counsel at trial holding that the fourteenth amendment incorporated the sixth amendment right to counsel holding that the sixth amendment right to counsel embodies the right to effective assistance of counsel recognizing that the sixth amendment guarantees a defendant the right to counsel and the right to waive counsel