The Supreme Court effectively set an expiration date on the right to counsel invocation by announcing a new 14-day break in custody rule in:

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The Supreme Court announced the new 14-day break in custody rule in Maryland v. Shatzer, which effectively set an expiration date on the right to counsel invocation. The Court ruled that if a suspect has been released from custody for at least 14 days and then re-interrogated, a prior invocation of the right to counsel is no longer valid and the suspect must be given a new opportunity to invoke the right.

The Supreme Court Effectively Set an Expiration Date on the Right