In Escobedo v. Illinois, 378 U.S. 478 (1964), the accused repeatedly requested and was denied access to counsel, prior to being formally indicted, but after being taken into police custody and subjected to interrogations aimed toward eliciting incriminating statements. The United States Supreme Court found that in these circumstances, the accused was denied the might to counsel since the investigation had ceased to be a general inquiry into an unsolved crime and had begun to focus on a particular suspect. Id., 378 U.S. at 490.