Law enforcement officers are free to approach a defendant for custodial interrogation who has appeared before a magistrate at the jail, so long as they first read the suspect his Miranda rights and obtain a waiver of counsel as is done under standard Miranda rules. With this decision, overruling Michigan v. Jackson (prohibiting interrogation of a defendant who invoked his right to counsel at arraignment), the Supreme Court allows for a bypass of the issue created in Rothgery (where magistration created protection under the Sixth Amendment with regard to right to counsel). The Court said, "What matters for Miranda and Edwards is what happens when the defendant is approached for interrogation, and (if he consents) what happens during the interrogation - not what happened at any preliminary hearing." Montejo v. Louisiana