Maryland v. Shatzer
Citation
559 U.S. 98 (2010). Supreme Court of the United States.
Facts
Michael Shatzer invoked his right to counsel during an interrogation about alleged child sexual abuse and questioning ceased. He was released back to the general prison population (he was serving time on an unrelated conviction). Two and a half years later, police re-approached him about the same case. After being given fresh Miranda warnings, Shatzer waived his rights and made incriminating statements.
Issue
Does Edwards v. Arizona’s prohibition on further interrogation after a suspect invokes the right to counsel continue indefinitely, or does a break in custody reset the Edwards protection?
Holding
The Court held that a break in Miranda custody of at least 14 days eliminates the Edwards presumption that any subsequent waiver of Miranda rights is involuntary. Return to the general prison population after invoking right to counsel constitutes a break in Miranda custody for Edwards purposes.
Rule / Doctrine
Edwards v. Arizona: once a suspect invokes the right to counsel, police may not reinitiate interrogation. Shatzer creates a 14-day bright-line exception: if the suspect has been released from the Miranda-custody setting for at least 14 days, the presumption of involuntariness dissipates and a fresh Miranda waiver is valid. General prison population is not Miranda custody for this purpose because inmates can seek legal counsel, contact family, and are not subject to the relentless interrogation pressure Edwards was designed to prevent.
Significance
Shatzer introduced the first time-based limit on Miranda’s anti-badgering rule, balancing suspect protection with law enforcement’s ability to pursue investigations over time. The 14-day rule is a rare bright-line in Fifth Amendment doctrine.