during a criminal interrogation, and only if the person was taken into police custody—the right was intended to prevent coercion and intimidation. Even fewer knew the Sixth Amendment embodied a second constitutional right to counsel when a prosecutor commenced a criminal prosecution by filing a complaint, or the suspect was indicted by a grand jury. The fallacy most Americans harbored was that they could simply shout, “I want a lawyer!” when confronted by a police officer, and the officer couldn’t talk to them. Not so.

