are indigent. A police interrogation must stop if the suspect states that he or she wishes to remain silent. In re Gault, Juvenile defendants are protected under the Due Process Clause of the Fourteenth Amendment. Michigan v. Jackson, If a police interrogation begins after a defendant asserts his or her right to counsel at an arraignment or similar proceeding, then any waiver of that right for that police-initiated interrogation is invalid (overruled by Montejo v. Louisiana (2009)). Montejo v. Louisiana, A defendant may waive his or her right to counsel during a police interrogation even if the interrogation begins after the defendant's assertion of his or her right to counsel at an arraignment or similar proceeding. Other rights regarding counsel Strickland v. Washington, To obtain relief due to ineffective assistance of counsel, a criminal defendant must show that counsel's performance fell below an objective standard of reasonableness and that counsel's deficient performance gives rise to a reasonable probability that, if counsel had performed adequately, the result of the proceeding would have been different. Padilla v. Kentucky, Criminal defense attorneys are duty-bound to inform clients of the risk of deportation under three circumstances. First, where the law is unambiguous, attorneys must advise their criminal clients that deportation "will" result from a conviction. Second, where the immigration consequences of a conviction are unclear or uncertain, attorneys must advise that deportation "may" result. Finally, attorneys must give their clients some advice about deportation—counsel cannot remain silent about immigration consequences. Right to remain silent Berghuis v. Thompkins, The right to remain silent does not exist unless a suspect invokes it unambiguously. Salinas v. Texas, The Fifth Amendment's protection against self-incrimination does not protect an individual's refusal to answer questions asked by law enforcement before he or she has been arrested or given the Miranda warning. A witness cannot invoke the privilege by simply standing mute; he or she must expressly invoke it. Competence Dusky v. United States, A defendant has the right to a competency evaluation before proceeding to trial. Rogers v. Okin, 478 F. Supp. 1342 (D. Mass. 1979) The competence of a committed patient is presumed until he or she is adjudicated incompetent. Ford v. Wainwright, A defendant has the right to a competency evaluation before being executed. Godinez v. Moran, A defendant who is competent to stand trial is automatically competent to plead guilty or waive the right to legal counsel.