The sixth amendment guarantees to the accused in a criminal prosecution the right to have the Assistance of Counsel for his defence. In Massiah v. United States, the Supreme Court held this right was violated when there was used against the defendant at trial evidence of incriminating statements deliberately elicited from him by an informant after he had been indicted and in the absence of counsel. In effect, this decision and others that \u27followed have created a new constitutional right not to be questioned about pending charges prior to trial except in the presence of an attorney. One consequence of the Massiah line of cases is that federal and state investigators may not use otherwise legitimate investigative methods to obtain incri...