"[1] Legal scholars have criticized this case stating that the "bright line" rule established under Edwards v. Arizona is preferable.

However, his conviction was affirmed when his request for counsel was reviewed and deemed ambiguous, and it was concluded that the NIS indeed clarified his intentions before continuing with questioning.

Thus, the Supreme Court ruled that an ambiguous and unclear request for counsel, such as David's “Maybe I should talk to a lawyer”, does not establish the right.

Justice O’Connor understood that fear, intimidation, and lack of linguistic and interrogation knowledge may affect the way the defendant requests a lawyer.

[9] In another case, People v. Krueger, Michael Krueuger claims investigators continued to question him after his request to counsel, thus violating his Miranda rights.