only if the authorities have “scrupulously honored” the accused’s right to terminate questioning. Mosley, 423 U.S. at 103, 96 S.Ct. at 326. In Edwards v. Arizona, 451 U.S. 477, 101 S.Ct. 1880, 68 L.Ed.2d 378 (1981), the Court clarified a distinction between asserting the right to remain silent and asserting the right to counsel. The Court established a bright-line rule: when an accused, in a custodial setting, invokes the right to counsel, the police must immediately cease all interrogation and may not resume questioning without the presence of counsel. See id. at 484-85, 101 S.Ct. at 1884-85. Bright-line rule or not, Edwards has sometimes been treated grudgingly by the Court. See, e.g., Connecticut v. Barrett, 479 U.S. 523, 529-30, 107 S.Ct. 828, 832-33, 93 L.Ed.2d 920 (1987) (<HOLDING>). More to the present point, in the eleven
holding that a federal criminal defendant may waive jury trial without advice of counsel holding that trial counsel was not ineffective when he failed to introduce defendants prior consistent statement statement was not admissible because it was made after defendant had been arrested clearly not a time when the effect of the statement could not have been foreseen holding that admission of oral statements voluntarily made by accused after he had stated that he would not make a written statement without advice of counsel did not violate edwards holding that defendants statements not admissible once he had invoked right to counsel without proof of waiver holding admissible suspects statement to police after being informed that he had been identified in a lineup which the court assumed without deciding was interrogation for purposes of the appeal because the statements were voluntarily made without any coercion and came after the suspect was given and validly waived his miranda rights