The right to counsel at pretrial criminal proceedings protects the accused from providing an involuntary confession, ensures that the Government affords the accused from inadvertent self-incrimination. Waiver of this right must be voluntary, knowing, and intelligent; and an initial waiver can be revoked if the accused indicates in any manner that he or she wishes to consult with an attorney before speaking. Courts have struggled to create a standard to determine when an accused's equivocal reference to an attorney constitutes an invocation of the right to counsel. In addressing this issue, the courts have used three approaches. The first requires that the accused's reference to an attorney reach a threshold standard of clarity before it invokes the right. Courts adhering to the second approach hold that upon any reference to counsel by the accused, all interrogation must immediately cease and may not continue until counsel is present. The third approach requires that an accused's equivocal reference to an attorney result in a limitation of further interrogation to attempts to determine if the accused does or does not desire counsel. It is argued that the last approach, the application of which seeks to clarify the accused's actual desires regarding counsel, best serves Miranda goals by providing interrogating officers with objective guidelines while protecting the accused from self-incrimination. 209 footnotes.