In Montejo v. Louisiana, 556 U.S. 778 (2009), the defendant did not request counsel but stood mute at his preliminary hearing required by Louisiana law, at which the court nevertheless ordered counsel appointed under its state procedural rules. Three hours later, and before Montejo could meet with counsel, detectives visited him in prison and read him his Miranda rights, after which he accompanied them on an excursion to locate the murder weapon and wrote an inculpatory letter of apology to the victim. Montejo sought to suppress the letter of apology as evidence at trial by extending Michigan v. Jackson to his situation--in which counsel had been appointed even though not expressly requested. The Louisiana Supreme Court held that an actual request for counsel or other assertion of the Sixth Amendment was required to trigger the Jackson rule presuming invalidity of any waiver of the Sixth Amendment right to counsel. The United States Supreme Court considered that approach of limiting Jackson to cases in which the defendant actually requests counsel at his first preliminary hearing, but the Court noted its unfairness in over half of the states in which counsel is automatically appointed at preliminary hearings such that defendants in those states have no opportunity to invoke the right to counsel themselves. But the Court also refused to extend Jackson's presumption to cases in which no request is made but counsel has been appointed or the defendant is otherwise represented. Refusing to accept either approach, the Court instead sua sponte re-evaluated Jackson and concluded that Jackson's extension of the Edwards bright-line rule to the Sixth Amendment right to counsel is "unworkable." Significantly, the Court based its decision, in large part, on its conclusion that the Sixth Amendment right to counsel is adequately protected by the existing guarantees of the Fifth Amendment by virtue of Miranda and Edwards, and because, under a cost-benefit analysis, the "substantial costs" of adding the exclusionary rule of Jackson on top of those in Miranda and Edwards far outweigh any "marginal benefits." Accordingly, the Montejo Court held: "Michigan v. Jackson should be and now is overruled."