In Davis v. United States (1994) 512 U.S. 452, 462, the suspect's statement, "Maybe I should talk to a lawyer," was held not to be an invocation of his Miranda rights. The court concluded that "if a suspect makes a reference to an attorney that is ambiguous or equivocal in that a reasonable officer in light of the circumstances would have understood only that the suspect might be invoking the right to counsel," the police may continue their questioning. ( Id. at p. 459.) The United States Supreme Court held that in order to effectively invoke the right to counsel, a suspect must: "Articulate his desire to have counsel present sufficiently clearly that a reasonable police officer in the circumstances would understand the statement to be a request for an attorney. . . . If the suspect's statement is not an unambiguous or unequivocal request for counsel, the officers have no obligation to stop questioning him." Id. at 459-60.