Does the word "attorney" constitute a waiver of a defendant's right to counsel?

Of course, Cheely does not necessarily invoke his rights simply by saying the magic word "attorney"; that word "has no talismanic qualities," and "[a] defendant does not invoke his right to counsel any time the word falls from his lips." United States v. Jardina, 747 F.2d 945, 949 (5th Cir.1984), cert. denied, 470 U.S. 1058, 105 S.Ct. 1773, 84 L.Ed.2d 833 (1985). Similarly, an express written or oral waiver of the right to counsel "is not inevitably either necessary or sufficient to establish waiver." North Carolina v. Butler, 441 U.S. 369, 373, 99 S.Ct. 1755, 1757, 60 L.Ed.2d 286 (1979).