In the first case described here, a suspect was questioned about his possible participation in a murder after he initially waived his right to a lawyer and after he suggested that perhaps he should speak to a lawyer; the interrogation stopped once the suspect invoked his constitutional right to see a lawyer before answering further questions. A judge denied the suspect's motion to suppress statements made at the interview, holding that his initial mention of a lawyer was not a request for counsel. His conviction on charges of unpremeditated murder was upheld by the U.S. Supreme Court, which ruled that officers have no obligation to stop questioning a suspect if his request for counsel is ambiguous or equivocal. This article discusses three approaches developed by the courts -- per se bar, threshold clarity approach, and clarifying questions approach -- toward assessing whether ambiguous or equivocal requests for counsel are sufficient to invoke a suspect's Miranda rights. The author concludes that the Supreme Court ruling has narrowed the scope of Miranda safeguards, and proposes a rule which would require interrogators to verify whether a suspect under custodial interrogation is expressing a desire to have counsel present. 101 notes