13 M.J. 408, 414 (C.M.A.1982) (quotation marks omitted)); see, e.g., Francis A. Gilligan, The Bill of Rights and Service Members, 1987 Army Law. 3, 10 (Dec.1987) (servicemembers’ rights broader than constitutionally required). 20 . 10 U.S.C. § 831 (2000). 21 . Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966). 22 . H.F. “Sparky” Gierke, The Use of Article III Case Law in Military Jurisprudence, Army Law., Aug. 2005, at 25, 36. 23 . United States v. Tulloch, 47 M.J. 283, 287 (C.A.A.F.1997) (declining to follow the Supreme Court’s holding in Purkett v. Elem, 514 U.S. 765, 769, 115 S.Ct. 1769, 131 L.Ed.2d 834 (1995), that the explanation for the challenge need not ”make[] sense”). 24 . Minnick v. Mississippi, 498 U.S. 146, 111 S.Ct. 486, 112 L.Ed.2d 489 (1990) (<HOLDING>). 25 . McNeil v. Wisconsin, 501 U.S. 171, 111
holding that unless suspect clearly requests counsel police do not have to halt questioning holding that once a suspect has requested counsel interrogators may not reinitiate questioning unless the attorney is present regardless of whether or not there has been an outside consultation holding that once a suspect has invoked his right to counsel police may still legitimately inquire whether the suspect has changed his mind about speaking to them without an attorney holding that although interrogation may not continue after a suspect has requested counsel the police legitimately may inquire whether the suspect has changed his mind about speaking to them without an attorney holding suspect must unambiguously request counsel before applying rule established in edwards that police questioning must cease once suspect requests counsel during interview