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Maryland v. Shatzer

Supreme Court of the United States · 2010 · Criminal Procedure

Criminal ProcedureMirandaEdwards rulecustodial interrogationright to counselEdwards v. ArizonaMiranda custodybreak in custody

Facts

In 2003, while serving a sentence for an unrelated offense in a Maryland prison, Shatzer was questioned about allegations that he had sexually abused his son. After initially waiving his Miranda rights, he declined to speak without an attorney, so the detective ended the interview and Shatzer was returned to the general prison population. About two and a half years later, after the investigation was reopened, another detective interviewed Shatzer at a different correctional institution, gave fresh Miranda warnings, obtained a written waiver, and elicited incriminating statements. Five days later, after another Miranda waiver, Shatzer made an additional inculpatory statement before requesting an attorney, at which point questioning ceased.

Issue

Does the Edwards presumption barring police-initiated custodial interrogation after a suspect requests counsel continue indefinitely, or does it end after a break in Miranda custody? If a break-in-custody exception exists, does a sentenced prisoner's return to the general prison population constitute such a break?

Rule

When a suspect invokes the Miranda right to counsel, Edwards bars police-initiated custodial interrogation only until the suspect has experienced a break in Miranda custody lasting 14 days or more, unless the suspect initiates further communication earlier. A sentenced prisoner's release from interrogation back into the general prison population constitutes a break in Miranda custody because lawful imprisonment after conviction does not itself create the coercive pressures that justify Edwards.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Police in Columbus, Ohio arrested Nina Patel on suspicion of arson. During custodial questioning at the station, she said she would not answer questions without a lawyer, so the detectives stopped. She was released the next morning, lived at home for 16 days, and then detectives asked to question her again, gave fresh Miranda warnings, and obtained a signed waiver.

Are Nina's later statements barred by the Edwards rule?

Explanation. Under the majority rule, Edwards creates a presumption that a waiver during later police-initiated custodial interrogation is involuntary after a suspect has invoked counsel, but that presumption ends after a break in Miranda custody lasting 14 days or more. A suspect released back to normal life for that period has had time to reacclimate, consult others, and shake off residual coercion. Because Nina was out of Miranda custody for 16 days before renewed questioning, Edwards does not itself bar the later interrogation, assuming the waiver was otherwise valid.