as much protection as the Fifth Amendment right to counsel at any custodial interrogation. Justice Stevens wrote, Edwards is grounded in the understanding that "the assertion of the right to counsel [is] a significant event," 451 U.S. at 451 U.S. 485, and that "additional safeguards are necessary when the accused asks for counsel." Id. at 451 U.S. 484. We conclude that the assertion is no less significant, and the need for additional safeguards no less clear, when the request for counsel is made at an arraignment and when the basis for the claim is the Sixth Amendment. We thus hold that, if police initiate interrogation after a defendant's assertion, at an arraignment or similar proceeding, of his right to counsel, any waiver of the defendant's right to counsel for that police-initiated interrogation is invalid. Although the Edwards decision itself rested on the Fifth Amendment and concerned a request for counsel made during custodial interrogation, the Michigan Supreme Court correctly perceived that the reasoning of that case applies with even greater force to these cases. Chief Justice Burger, concurred in the judgment saying that stare decisis called for "following the rule of Edwards in this context, but plainly the subject calls for reexamination." Dissent Justice Rehnquist wrote a dissenting opinion joined by Justice Powell and Justice O'Connor. The dissent explained, Edwards did not confer a substantive constitutional right that had not existed before; it 'created a protective umbrella serving to enhance a constitutional guarantee.' The prophylactic rule of Edwards, designed from its inception to protect a defendant's right under the Fifth Amendment not to be compelled to incriminate himself, simply does not meaningfully apply to the Sixth Amendment. Aftermath The holding in Michigan v. Jackson was narrowed later by the Court in McNeil v. Wisconsin, which held that an accused's invocation of his Sixth Amendment right to counsel during a judicial proceeding does not constitute an invocation of the right to counsel derived by Miranda v. Arizona, from the Fifth Amendment's guarantee against compelled self-incrimination. "Therefore, while a defendant who has invoked his Sixth Amendment right to counsel with respect to the offense for which he is being prosecuted may not waive that right, he may waive his Miranda–based right not to be interrogated about unrelated and uncharged offenses." Also the Court held in Michigan v. Harvey that evidence acquired in violation of Michigan v. Jackson could be used for impeachment