MARYLAND v. SHATZER

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Case Basics
Docket No. 
08-680
Petitioner 
Maryland
Respondent 
Michael Blaine Shatzer, Sr.
Advocates
(Attorney General of Maryland argued the cause for the petitioner)
(Assistant to the Solicitor General, Department of Justice, for the United States, as amicus curiae, supporting the petitioner)
(argued the cause for the respondent)
Term:
Facts of the Case 

In August 2003, a detective from the Hagerstown, MD Police Department interviewed Michael Blain Shatzer Sr. regarding allegations that he had sexually abused his three-year old child. At the time, Mr. Shatzer was incarcerated on an unrelated offense involving sexual abuse of another child. After Mr. Shatzer invoked his Fifth Amendment rights to counsel and to remain silent, the interview was terminated. The investigation was subsequently closed, only to be reopened in January 2006 on the prompting of Mr. Shatzer's wife, when she recognized her child could make more specific allegations about Mr. Shatzer's alleged sexual abuse. Thereafter in March 2006, another detective from the Hagerstown Police Department, who was aware that Mr. Shatzer had been under investigation, but was not aware that Mr. Shatzer had previously invoked his Fifth Amendment rights to counsel and to remain silent, interviewed him. At this interview, Mr. Shatzer was advised of his Fifth Amendment rights, which he waived, and then confessed to specific instances of sexual abuse involving his child.

Prior to trial, Mr. Shatzer moved to suppress the confessions he made in the March 2006 interview arguing that his 2003 invocation of his Fifth Amendment rights was still applicable. Under Edwards v. Arizona rendered the confession inadmissible. The motion was denied and a Maryland trial court convicted him of sexual child abuse. On appeal, the Court of Appeals of Maryland reversed, holding that the protections of Edwards applies for an inmate who has been continually incarcerated and had previously invoked his Fifth Amendment rights, until either counsel is made available or the inmate initiates further conversation with police. Therefore, under the circumstances, Mr. Shatzer's confession was inadmissible.

Question 

Does Edwards v. Arizona prohibit the re-interrogation of a suspect, who has invoked his Fifth Amendment rights to counsel and to remain silent, after a substantial amount of time has elapsed between the invocation of rights and the subsequent interrogation?

Conclusion 
Decision: 9 votes for Maryland, 0 vote(s) against
Legal provision: Miranda warnings

No. The Supreme Court reversed the Court of Appeals of Maryland, holding that because Mr. Shatzer experienced a break in Miranda custody lasting more than two weeks between the first and second attempts at interrogation, Edwards does not mandate suppression of his 2006 statements. Justice Antonin G. Scalia writing for the majority reasoned that when a suspect has been released from custody and returned to normal life before the police later attempt interrogation, there is little reason to believe that the suspect's change of heart was coerced. The Court then stated that the appropriate period of time for a person to be re-acclimated to normal life was 14 days. Here, even though Mr. Shatzer was released back into the general prison population, he entered back into his normal life and was free of the pressures of investigative custody; thus, the Edwards presumption was no longer warranted.

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MARYLAND v. SHATZER. The Oyez Project at IIT Chicago-Kent College of Law. 23 October 2014. <http://www.oyez.org/cases/2000-2009/2009/2009_08_680>.
MARYLAND v. SHATZER, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2009/2009_08_680 (last visited October 23, 2014).
"MARYLAND v. SHATZER," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 23, 2014, http://www.oyez.org/cases/2000-2009/2009/2009_08_680.