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kicks in at commencement of judicial proceedings; policy becomes not dispelling of coercive atmosphere, but protection of adversarial nature of CJ system.

deliberate elicitation of information constitutes an interrogation under the 6th Amd. 

deliberate = likely to induce a response

must be more than passive listening

Miranda warnings appropriate for 6th Amendment waiver; Zerbst + inform that lawyer has been retained if that is the case

6th Amd version of Edwards- once right to counsel invoked, questioning must cease till counsel present

6th Amd. rights are "charged crime" specific; Blockburger doctrine- if two crimes have same statutory elements, then they are the same crime for a Cobb analysis.