Maryland v. Shatzer
Encyclopedia
Maryland v. Shatzer, No. 08-680
(2010), was a case in which the Supreme Court of the United States
held that police may re-open questioning of a suspect who has asked for counsel (thereby under Edwards v. Arizona
ending questioning) if there has been a 14-day or more break in Miranda custody
. The ruling distinguished Edwards, which had not specified a limit.
, the Supreme Court held that statements of criminal suspects made while they are in custody and subject to interrogation by any government authority may not be admitted in court unless the suspect first had certain warnings read to him beforehand. In Edwards v. Arizona
, the Supreme Court further clarified that once a suspect had invoked their right to have an attorney present police questioning must cease. Left unanswered was how long this protection applied—when could police resume questioning?
Michael Shatzer, the respondent in the case, was an inmate in the Maryland penal system, serving time for child sexual abuse. In 2003 police desired to question Shatzer about allegations that he had sexually abused his son. Shatzer declined to speak without his attorney present, at which point the interview ended (per Edwards). The police closed the investigation and Shatzer returned to the prison population. Three years later the police opened a new investigation and again asked to question Shatzer. This time Shatzer waived his right to have an attorney present; only after making incriminating statements did Shatzer ask for an attorney. With this evidence in hand, Shatzer was convicted of sexual child abuse by the Washington County, Maryland
circuit court. The court denied Shatzer's motion to suppress his confession, reasoning that the three years between the two interviews counted as a break in custody.
On appeal, the Court of Appeals of Maryland reversed, holding that even if there were a break in custody exception to Edwards, being released back into the prison population would not constitute such. The state of Maryland petitioned the Supreme Court for a writ of certiorari, which was granted on January 26, 2009.
delivered the opinion of the court, joined by Chief Justice Roberts and Justices Kennedy
, Ginsburg
, Breyer
, Alito
and Sotomayor
. Justice Thomas
joined as to part III only and filed an opinion concurring in part and concurring in judgment. Justice Stevens
also filed an opinion concurring in judgment.
The court divided its opinion into four parts. Part I reviewed the prior history of the case before the court. In Part II the court explained that the Miranda rule, while not a constitutional guarantee itself, served as a "prophylactic" for a suspect's Fifth Amendment rights. This protection was augmented by Edwards, which required police to cease questioning once a suspect had asked for an attorney. The court noted that while it had never spoken on the question of a break in custody, lower courts had affirmed that there was such an exception, and as the court had promulgated the rule in the first place it was obliged to clarify the issue. The purpose of Edwards was to protect a suspect who found himself in unusual circumstances; extending the Edwards rule indefinitely would not meet this aim and have the effect of protecting repeat offenders who "acquired Edwards immunity previously in connection with any offense in any jurisdiction." Having declined to extend Edwards indefinitely, the court adopted a standard of 14 days. The court justified this period by noting that 14 days "provides plenty of time for the suspect to get reacclimated to his normal life, to consult with friends and counsel, and to shake off any residual coercive effects of his prior custody."
In Part III the court considered the specific facts of the case: under the newly qualified standards, did the three years between the two interviews, during which Shatzer was incarcerated, constitute a "break in custody"? The court held that it did: while in the general prison population, Shatzer was free from the coercive power of an interrogator.
In Part IV the court responded to claims made by Justice Stevens in his dissent that the majority opinion underestimated the coercive effect of a police interrogator re-opening a line of questioning after a break in custody.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2010), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that police may re-open questioning of a suspect who has asked for counsel (thereby under Edwards v. Arizona
Edwards v. Arizona
Edwards v. Arizona, 451 U.S 477 , is a decision by the United States Supreme Court holding that once a defendant invokes his Fifth Amendment right to counsel police must cease custodial interrogation...
ending questioning) if there has been a 14-day or more break in Miranda custody
Miranda warning
The Miranda warning is a warning given by police in the United States to criminal suspects in police custody before they are interrogated to preserve the admissibility of their statements against them in criminal proceedings. In Miranda v...
. The ruling distinguished Edwards, which had not specified a limit.
Background
In Miranda v. ArizonaMiranda v. Arizona
Miranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
, the Supreme Court held that statements of criminal suspects made while they are in custody and subject to interrogation by any government authority may not be admitted in court unless the suspect first had certain warnings read to him beforehand. In Edwards v. Arizona
Edwards v. Arizona
Edwards v. Arizona, 451 U.S 477 , is a decision by the United States Supreme Court holding that once a defendant invokes his Fifth Amendment right to counsel police must cease custodial interrogation...
, the Supreme Court further clarified that once a suspect had invoked their right to have an attorney present police questioning must cease. Left unanswered was how long this protection applied—when could police resume questioning?
Michael Shatzer, the respondent in the case, was an inmate in the Maryland penal system, serving time for child sexual abuse. In 2003 police desired to question Shatzer about allegations that he had sexually abused his son. Shatzer declined to speak without his attorney present, at which point the interview ended (per Edwards). The police closed the investigation and Shatzer returned to the prison population. Three years later the police opened a new investigation and again asked to question Shatzer. This time Shatzer waived his right to have an attorney present; only after making incriminating statements did Shatzer ask for an attorney. With this evidence in hand, Shatzer was convicted of sexual child abuse by the Washington County, Maryland
Washington County, Maryland
Washington County is a county located in the western part of the U.S. state of Maryland, bordering southern Pennsylvania to the north, northern Virginia to the south, and the Eastern Panhandle of West Virginia to the south and west. As of the 2010 Census, its population is 147,430...
circuit court. The court denied Shatzer's motion to suppress his confession, reasoning that the three years between the two interviews counted as a break in custody.
On appeal, the Court of Appeals of Maryland reversed, holding that even if there were a break in custody exception to Edwards, being released back into the prison population would not constitute such. The state of Maryland petitioned the Supreme Court for a writ of certiorari, which was granted on January 26, 2009.
Opinion
Justice ScaliaAntonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...
delivered the opinion of the court, joined by Chief Justice Roberts and Justices Kennedy
Anthony Kennedy
Anthony McLeod Kennedy is an Associate Justice of the United States Supreme Court, having been appointed by President Ronald Reagan in 1988. Since the retirement of Sandra Day O'Connor, Kennedy has often been the swing vote on many of the Court's politically charged 5–4 decisions...
, Ginsburg
Ruth Bader Ginsburg
Ruth Joan Bader Ginsburg is an Associate Justice of the Supreme Court of the United States. Ginsburg was appointed by President Bill Clinton and took the oath of office on August 10, 1993. She is the second female justice and the first Jewish female justice.She is generally viewed as belonging to...
, Breyer
Stephen Breyer
Stephen Gerald Breyer is an Associate Justice of the U.S. Supreme Court. Appointed by President Bill Clinton in 1994, and known for his pragmatic approach to constitutional law, Breyer is generally associated with the more liberal side of the Court....
, Alito
Samuel Alito
Samuel Anthony Alito, Jr. is an Associate Justice of the U.S. Supreme Court. He was nominated by President George W. Bush and has served on the court since January 31, 2006....
and Sotomayor
Sonia Sotomayor
Sonia Maria Sotomayor is an Associate Justice of the Supreme Court of the United States, serving since August 2009. Sotomayor is the Court's 111th justice, its first Hispanic justice, and its third female justice....
. Justice Thomas
Clarence Thomas
Clarence Thomas is an Associate Justice of the Supreme Court of the United States. Succeeding Thurgood Marshall, Thomas is the second African American to serve on the Court....
joined as to part III only and filed an opinion concurring in part and concurring in judgment. Justice Stevens
John Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
also filed an opinion concurring in judgment.
The court divided its opinion into four parts. Part I reviewed the prior history of the case before the court. In Part II the court explained that the Miranda rule, while not a constitutional guarantee itself, served as a "prophylactic" for a suspect's Fifth Amendment rights. This protection was augmented by Edwards, which required police to cease questioning once a suspect had asked for an attorney. The court noted that while it had never spoken on the question of a break in custody, lower courts had affirmed that there was such an exception, and as the court had promulgated the rule in the first place it was obliged to clarify the issue. The purpose of Edwards was to protect a suspect who found himself in unusual circumstances; extending the Edwards rule indefinitely would not meet this aim and have the effect of protecting repeat offenders who "acquired Edwards immunity previously in connection with any offense in any jurisdiction." Having declined to extend Edwards indefinitely, the court adopted a standard of 14 days. The court justified this period by noting that 14 days "provides plenty of time for the suspect to get reacclimated to his normal life, to consult with friends and counsel, and to shake off any residual coercive effects of his prior custody."
In Part III the court considered the specific facts of the case: under the newly qualified standards, did the three years between the two interviews, during which Shatzer was incarcerated, constitute a "break in custody"? The court held that it did: while in the general prison population, Shatzer was free from the coercive power of an interrogator.
In Part IV the court responded to claims made by Justice Stevens in his dissent that the majority opinion underestimated the coercive effect of a police interrogator re-opening a line of questioning after a break in custody.