This Note discusses Covarrubias' facts and procedural history. Part III outlines the history of the Sixth Amendment right to counsel, with an emphasis on the inextricably intertwined exception. Part IV analyzes the Ninth Circuit's reasoning in Covarrubias. Part V critiques this reasoning in light of the strong presumption against the finding of the application of the inextricably intertwined exception. Finally, Part VI concludes that the Ninth Circuit properly suppressed the defendant's incriminating statements obtained by I.N.S. Agent Gonzalez, but would have set forth a stronger position had the Ninth Circuit evaluated in addition, or, in the alternative, under the circumvention of right exception.
United States v. Covarrubias: Does the Ninth Circuit Add to the Ambiguity of the Inextricably Intertwined Exception?, 30 Golden Gate U. L. Rev.