"The requirement of an `initiation'ensures that an accused has independently changed his or her mind about the need for a lawyer, and has not had his or her mind changed by the coercive pressures of continued direct questioning or its functional equivalent. "

In that case the Arizona Supreme Court assumed no interrogation and assumed the suspect waived his rights under Miranda

For this review, we have considered those cases in which the trial judge sentenced the defendant to death based upon a finding of two aggravating circumstances and no mitigating circumstances sufficiently substantial to require lenience

—noting that the lower court “made no findings as to whether James' statement was an 'initiation' under Edwards or a response to interrogation as defined in Innis

—the police had just subjected the suspect to interrogation, and the suspect thought the police had directed the question to him.

Although the courts in each of these states have approved especially heinous findings in cases involving serious physical abuse

The denial of his petition adds to a long line of cases in which the Court has declined to review capital sentences marred by the sort of violation described here

—and our Rule 4.5, law enforcement was obligated to "scrupulously honor" his assertion of his rights and should have refrained from continuing to ask Robinson about the crime.

Since the Miranda decision, many Supreme Court decisions have cited to the Miranda court's use of the Reid Model as influencing the Court's reasoning in that decision.

[CITATION] Watkins v. Virginia