Does a defendant have a right to make a written statement without counsel?

"New York", United States of America

The following excerpt is from People v. Hendricks, 665 N.Y.S.2d 45, 90 N.Y.2d 956 (N.Y. 1997):

Defendant's reliance on Connecticut v. Barrett, 479 U.S. 523, 107 S.Ct. 828, 93 L.Ed.2d 920, is misplaced as defendant's refusal to give a written statement did not implicate his right to counsel (cf., Connecticut v. Barrett, supra [where defendant agreed to talk but refused to make a written statement without counsel, defendant's invocation of his right to counsel was limited to the making of written statements and oral statement was admissible] ).

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