In Connecticut v. Barrett, 479 U.S. 523 (1987), the United States Supreme Court rejected the notion that a defendant's request for counsel before making a written statement invoked the right to counsel for all purposes. As nothing "requires authorities to ignore the tenor or sense of a defendant's response to Miranda warnings," the Court found that the Connecticut Supreme Court erred in finding that "a limited invocation of defendant's right to counsel prohibited all interrogation absent initiation of further discussion by defendant." The fundamental purpose of the Miranda decision is "'to assure that the individual's right to choose between speech and silence remains unfettered throughout the interrogation process.'" Id.