Maryland v. Shatzer
559 U.S. 98 (2010)
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Rule of Law:
The protections against police-initiated interrogation established in Edwards v. Arizona for a suspect who invokes their right to counsel cease to apply when there is a break in Miranda custody lasting at least 14 days. An inmate's release from interrogative custody back into the general prison population constitutes such a break in custody.
Facts:
- In August 2003, Michael Shatzer, Sr., was incarcerated at a Maryland correctional facility for an unrelated crime.
- Detective Shane Blankenship interviewed Shatzer at the facility regarding allegations that Shatzer had sexually abused his son.
- After being read his Miranda rights, Shatzer invoked his right to have an attorney present, at which point Blankenship immediately terminated the interview.
- Shatzer was returned to the general prison population, and the police department closed the investigation.
- Two years and six months later, in March 2006, the investigation was reopened based on new information.
- Detective Paul Hoover went to the new correctional facility where Shatzer was housed and initiated a second interview.
- Hoover administered a fresh set of Miranda warnings, and Shatzer signed a written waiver of his rights.
- During this second interview, Shatzer made an incriminating statement, admitting to masturbating in front of his son. Five days later, after a polygraph exam, he made another inculpatory statement.
Procedural Posture:
- The State of Maryland charged Michael Shatzer with sexual child abuse in the Circuit Court for Washington County, Maryland, a state trial court.
- Shatzer filed a motion to suppress his incriminating statements, arguing they were obtained in violation of Edwards v. Arizona.
- The trial court denied the motion, finding that a break in custody had occurred between the 2003 and 2006 interrogations.
- Following a bench trial on an agreed statement of facts, the trial court found Shatzer guilty.
- Shatzer, as appellant, appealed to the Court of Appeals of Maryland, the state's highest court.
- The Court of Appeals of Maryland reversed the conviction, holding that returning to the general prison population did not constitute a break in custody for Edwards purposes.
- The State of Maryland, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a break in custody lasting two and a half years, during which a suspect was returned to the general prison population, end the presumption of involuntariness for a subsequent police-initiated interrogation that was established in Edwards v. Arizona after the suspect initially invoked his right to counsel?
Opinions:
Majority - Justice Scalia
Yes. A break in custody lasting 14 days or more is sufficient to end the Edwards presumption against police-initiated interrogation. The Court reasoned that Edwards is a judicially created prophylactic rule, not a constitutional command, designed to prevent police from badgering a suspect during continuous custodial interrogation. The coercive pressures that justify the rule dissipate when a suspect is released from custody and allowed to reacclimate to their normal life. To provide law enforcement with clear guidance, the Court established a bright-line rule that a 14-day break is sufficient to end the Edwards protection. Furthermore, an incarcerated person's return to the general prison population constitutes a break in Miranda custody because they return to their 'accustomed surroundings and daily routine' and are no longer in the 'police-dominated atmosphere' that defines interrogative custody.
Concurring - Justice Thomas
Concurring in part and in the judgment, Justice Thomas agreed that Shatzer's return to the general prison population constituted a break in custody. However, he disagreed with the Court's creation of a 14-day prophylactic rule extending Edwards protections post-custody. He argued that the 14-day period is an arbitrary 'ipse dixit' that lacks a close fit with the Fifth Amendment's actual protections. In his view, the Edwards presumption, which he questions even in its original context, should not be extended beyond the moment a break in custody occurs.
Concurring - Justice Stevens
Concurring in the judgment, Justice Stevens agreed that the two-and-a-half-year break in this case was sufficient to render Edwards inapplicable, but he strongly disagreed with the majority's creation of a 14-day bright-line rule. He argued that the rule disregards the coercive effect of re-interrogating an indigent suspect who was promised a lawyer that was never provided, which makes the police promise of counsel seem like a lie. He also contended that prison is not 'normal life' and that returning to the general population does not dissipate the coercive pressures in the same way as being released to one's home. While the lengthy 2.5-year gap in this specific case justified the outcome, he found a mere 14-day rule to be arbitrary and insufficiently protective.
Analysis:
This decision significantly cabins the scope of the Edwards rule by establishing a clear, bright-line temporal limit on its application. By creating the 14-day break-in-custody rule, the Court provides law enforcement with a definitive timetable for when they can re-approach suspects who have invoked their right to counsel. The holding that an inmate's return to the general prison population constitutes a 'break in custody' is particularly impactful, as it substantially broadens police authority to investigate crimes committed by or involving incarcerated individuals. The case marks a shift toward prioritizing law enforcement's ability to obtain voluntary confessions over the prophylactic, court-created protections that had previously been interpreted more broadly.
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