The sixth amendment of The United States Constitution provides: "[I]n all criminal prosecutions, the accused shall enjoy the right . . . to have Assistance of Counsel for his defence." The constitutional guarantee of right to counsel is no more explicit than this, thus creating the problem of determining at what point in our adversarial criminal system the guarantee attaches.
Extension of the Sixth Amendment Right to Counsel- The Road from Wade to Ash,
U. Rich. L. Rev.
Available at: https://scholarship.richmond.edu/lawreview/vol7/iss1/7