context: To decide the appropriate analytical framework for examining the validity of Robinson's, waiver, we have examined case law regarding the waiver of constitutional rights and the waiver of statutory rights. Generally, a waiver of a constitutional right must be knowing and voluntary.
citation_a.signal: see
citation_a.parenthetical: defendant must know of his Sixth Amendment right to counsel in order to validly waive it
citation_a.sentence: See, e.g., Johnson v. Zerbst, 304 U.S. 458, 468, 58 S.Ct. 1019, 1024, 82 L.Ed. 1461 (1938) (defendant must know of his Sixth Amendment right to counsel in order to validly waive it).
citation_b.signal: see also
citation_b.parenthetical: waiver of Fifth Amendment rights must be knowing and voluntary
citation_b.sentence: See also United States v. Wade, 388 U.S. 218, 237, 87 S.Ct. 1926, 1937, 18 L.Ed.2d 1149 (1967) (waiver of right to counsel’s presence during a lineup must be knowing and voluntary); Miranda v. Arizona, 384 U.S. 436, 469, 86 S.Ct. 1602, 1625, 16 L.Ed.2d 694 (1966) (waiver of Fifth Amendment rights must be knowing and voluntary).