In People v. Pitchford, 314 Ill. App. 3d 72, 79, 731 N.E.2d 323, 328-29, 246 Ill. Dec. 795 (2000), the defendant's retained counsel informed the police officers, prior to the defendant's arrest, that she was the defendant's attorney. She did not, however, appear at the police station during the police officers' questioning of the defendant. Pitchford, 314 Ill. App. 3d at 74, 731 N.E.2d at 325. On appeal, the defendant, relying on McCauley, argued that because the police officers knew the defendant had retained counsel, they violated the Illinois Constitution by interrogating him without his attorney present. Pitchford, 314 Ill. App. 3d at 78, 731 N.E.2d at 328. The appellate court rejected that argument: "Extending the McCauley rule to situations such as the instant case would place an undue burden on the police. Such a holding would impose a duty upon the police before undertaking any interrogation of a prisoner in their custody to contact the defendant's attorney if they were aware that he had an attorney. While that duty may not seem overly burdensome under the facts of the case at bar, it would set a troubling and problematic precedent. In order to avoid violating the defendant's rights under such a regime, the police would have to keep track of which suspects had retained counsel. Such a requirement would be especially burdensome if the knowledge of one police officer that a defendant was represented by counsel was imputed to the other officers in the department." Pitchford, 314 Ill. App. 3d at 79-80, 731 N.E.2d at 329.