What is the test for introducing evidence concerning a criminal defendant's statements?

MultiRegion, United States of America

The following excerpt is from U.S. v. Abshire, 34 F.3d 1074 (9th Cir. 1994):

1 Massiah v. United States, 377 U.S. 201 (1964), prohibits the introduction of evidence concerning a criminal defendant's statements when such evidence is obtained in a covert manner that deprives the defendant of the benefits of counsel.

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