Nicole and Shania were contemplating robbing the local bank. They purchased handguns and tools to break into the bank's vault. As they approached the bank's entrance, they became afraid and started to run away, but astute police officers noticed their suspicious behavior, chased after the women, and arrested them. The officers notified the prosecutor, who wrote an information charging both women with attempted robbery. The women filled out forms that indicated they were indigent and in need of appointed counsel. They appeared before the judge, who read the charges aloud in court and appointed counsel for each woman.

The women were returned to jail and placed in separate cells. Police came to see Shania and asked if she would like to speak to them. They read Shania her Miranda rights, but she said nothing, and the officers left. In Nicole's cell, police placed an informant, Ellie. Ellie struck up a conversation with Nicole and asked, "What did you do to get yourself in this mess?" Nicole told Ellie about the plot to rob the bank. Before trial, both women raised claims that their Sixth Amendment right to counsel had been violated. Are they correct?

(Using IRAC, discuss the role of Montejo and Massiah precedents, deliberate elicitation rule).