Escobedo v. Illinois

The Sixth Amendment guarantees that in all criminal prosecutions the "accused shall enjoy the right . . . to have compulsory process for obtaining Witnesses in his favor, and to have Assistance of Counsel for his defense."

Yet, courts have struggled with deciding exactly when this right begins, especially in cases where the accused confesses during interrogation and then recants. In Crooker v. California the defendant confessed after he refused to be appointed counsel. The court ruled that the confession was voluntary and dismissed the defendant's argument that he had a right to counsel at the police station.

Later in Cicencia v. La Gay when the defendant was found guilty after having been denied access to his attorney at the police station, the Court upheld the conviction. In White v. Maryland the absolute right to counsel in a capital case was held applicable to a pretrial proceedings, such as preliminary arrangements.