Read the following excerpt from a US court opinion:
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showing only that he responded to further police-initiated custodial interrogation even if he has been advised of his rights_[Rather,] an accused, ... having expressed his desire to deal with the police only through counsel, is not subject to further interrogation by the authorities until counsel has been made available to him, unless the accused himself initiates further communication, exchanges, or conversations with the police. Id. at 484-85, 101 S.Ct. at 1884-85; see also Minnick v. Mississippi 498 U.S. 146, 153, 111 S.Ct. 486, 491, 112 L.Ed.2d 489 (1990) (stating “that when counsel is requested, interrogation must cease, and officials may not reinitiate interrogation without counsel present, whether or not the accused has consulted with his attorney”); Savino, 82 F.3d at 599-600 . Polk, to whom Howard initially confessed, did
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What is the most suitable continuation to the opinion? Your options are:
A. holding that any confession obtained by interrogation reinitiated by police in the absence of counsel is inadmissible unless the defendant reinitiates discussion with police and then confesses
B. holding in a plurality opinion that a confession obtained through a twostep questions first interrogation technique whereby the police deliberately questioned a defendant in custody until that defendant confessed followed by a miranda warning and reiteration of the confession was inadmissible because the police strategy undermined the effectiveness of the miranda warning
C. holding that witness statements in police report inadmissible
D. recognizing that not all statements obtained by the police after a person has been taken into custody are to be considered the product of interrogation
E. holding that fifth amendment protection against selfincrimination requires police to notify suspect of right to counsel and to cut off interrogation once suspect invokes the right absent counsel further interrogation may not occur unless suspect initiates subsequent conversation if police initiate subsequent interrogation there can be no valid waiver of counsel even though police advise suspect of his or her constitutional rights and suspect acquiesces in the interrogation
Reply with [A, B, C, D, E] only.