In State v. Guthrie, 666 So. 2d 562 (Fla. 2d DCA 1995), the Second District held that a defendant's claim-of-rights form signed at a first appearance hearing on a grand theft charge precluded the police from questioning the defendant on unrelated allegations of sexual child abuse. The circuit court had suppressed Guthrie's confession to the child abuse charges and the district court affirmed the ruling because it concluded that the "invocation of the constitutional right to counsel bars uncounseled interrogation during continuous custody unless initiated by the defendant." 666 So. 2d at 562.