Ambiguous Request for Counsel In Arizona

In Arizona, when a request for counsel is ambiguous, police must limit any further questioning to clarify defendant's request. See State v. Finehout, 136 Ariz. 226, 229, 665 P.2d 570, 573 (1983); see also Inman, 151 Ariz. at 416, 728 P.2d at 286. In People v. Harris, 191 Colo. 234, 552 P.2d 10 (Colo. 1976), the Colorado Supreme Court held that the question, "When can I get a lawyer?" was an invocation of the accused's Miranda right to counsel. 552 P.2d at 11-13. In State v. Inman, 151 Ariz. 413, 728 P.2d 283 (App. 1986), the Court cited Harris in holding that a similar question was, "at the very least, . . . an ambiguous request for counsel that, without more, should have stopped all questioning except that which would have been necessary to clarify whether the accused wanted a lawyer before questioning." Inman, 151 Ariz. at 416, 728 P.2d at 286.