Michigan v. Jackson (1986) 475 U.S. 625, is overruled in cases where there was a subsequent waiver of counsel after the initial appointment. At a preliminary hearing, Montejo was charged with first-degree murder and the court appointed counsel. Later that same day, he was read his Miranda rights, and agreed to go on an excursion with police to locate the murder weapon. During the excursion, he wrote a letter of apology to the victim’s widow. Upon his return, he met his court-appointed counsel for the first time. At his trial, the letter was admitted over his objection, and he was convicted and sentenced to death. The Louisiana Supreme Court rejected his claim that the letter should have been suppressed under the rule of Michigan v. Jackson, which forbids police interrogation after the right to counsel has been invoked. It held that Jackson’s protection is not triggered unless the defendant has actually requested a lawyer or otherwise asserted his Sixth Amendment right, and here Montejo did not actually make the request or assertion. The United States Supreme Court held that Louisiana’s interpretation of Jackson would lead to practical problems in states which appoint counsel without request from the defendant. However, Montejo’s solution, that once a defendant is represented by counsel he may not be interrogated, is entirely untethered from the original rationale of Jackson. The Court overruled Jackson. It held that Montejo should be given an opportunity to contend that his letter of apology should have been suppressed under the Edwards v. Arizona (1980) 451 U.S. 477, rule. Since Montejo did not pursue an Edwards objection, since Jackson was broader, remand was required.