California, United States of America
The following excerpt is from People v. Coronado, B285683 (Cal. App. 2019):
10. Coronado does not argue that his Sixth Amendment right to counsel was violated. (See generally Massiah v. United States (1964) 377 U.S. 201.) The Sixth Amendment is " 'offense specific' " in that it applies to the subject of crimes for which " 'adversary judicial criminal proceedings have been initiated.' " (People v. Slayton (2001) 26 Cal.4th 1076, 1079.) Coronado had not been charged with the crimes in this case at the time he talked to Paredes.
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