context: . The United States Court of Appeals for the Ninth Circuit has recognized that "language dif-Acuities may impair the ability of a person in custody to waive [their Miranda rights] in a free and aware manner."
citation_a.signal: see also
citation_a.identifier: 790 F.2d 464, 469
citation_a.parenthetical: holding that accused's waiver of Miranda rights was unknowing and unintelligent where accused spoke broken English, had a deficient understanding of the English language and knew nothing about the American criminal justice system
citation_a.sentence: See also U.S. v. Short, 790 F.2d 464, 469 (6th Cir.1986) (holding that accused’s waiver of Miranda rights was unknowing and unintelligent where accused spoke broken English, had a deficient understanding of the English language and knew nothing about the American criminal justice system).
citation_b.signal: but see
citation_b.identifier: 6 F.3d 1360, 1365-66
citation_b.parenthetical: concluding that an accused who received Miranda warnings in Spanish and who then stated that he understood those rights knowingly and intelligently waived them
citation_b.sentence: But see U.S. v. Bautista-Avila, 6 F.3d 1360, 1365-66 (9th Cir.1993) (concluding that an accused who received Miranda warnings in Spanish and who then stated that he understood those rights knowingly and intelligently waived them).