State v. Lale
In State v. Lale. 141 Wisc. 2d 480, 415 N.W.2d 847 (Wis. Ct. App. 1987) the defendant was out on bail after being arrested for attempted murder. Although he had retained counsel for that charge, no complaint had been filed and so no formal adversary proceedings had begun. Several days later, a complaint was filed against him for possession of illegal weapons. That same day, officers contacted Lale's girlfriend and persuaded her to encourage Lale to talk to the police about the attempted murder.
The defendant complained that these conversations violated his Sixth Amendment right to counsel, but the court concluded that his right to counsel had not yet attached on the attempted murder.