What is the test for a defendant to invoke his right to counsel during questioning?

This court reviews for clear error a district court's factual findings concerning the words used by a defendant to invoke his right to counsel; whether those words invoke the right to counsel is reviewed de novo. United States v. Ogbuehi, 18 F.3d 807, 813 (9th Cir.1994).

A defendant has a right to terminate questioning by invoking his right to counsel; but the invocation, when viewed objectively, must be an unambiguous request for counsel. Davis v. United States, 114 S.Ct. 2350, 2355 (1994). "[Defendant] must articulate his desire to have counsel present sufficiently clearly that a reasonable police officer in the circumstances would understand the statement to be a request for an attorney." Id. See also Ogbuehi, 18 F.3d at 813 (interrogation must cease if defendant's words, as ordinary people would understand them, clearly indicate desire for counsel).