The following excerpt is from Cahill v. Rushen, 501 F. Supp. 1219 (E.D. Cal. 1980):
8 Of course, this is not to say that actual interrogation is not relevant in a Sixth Amendment case. Clearly "affirmative interrogation, absent waiver, would certainly satisfy Massiah ...." United States v. Henry, supra, 100 S.Ct. at 2187.
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