## Facts

- In 2003, a Maryland detective questioned Michael Blaine Shatzer, Sr., who was incarcerated on an unrelated conviction, about allegations of sexual abuse of his three-year-old son.
- Shatzer received *Miranda* warnings and invoked his right to have counsel present; the detective ended the interrogation.
- The investigation was closed, and Shatzer returned to the prison’s general population.
- In 2006, more than two and a half years later, a different detective reopened the investigation and sought to question Shatzer at the same facility.
- Shatzer was given fresh *Miranda* warnings, waived his rights, and made inculpatory statements.
- During the 2006 interrogation, Shatzer later requested an attorney and questioning ceased.
- The trial court denied Shatzer’s motion to suppress the 2006 statements, concluding a break in *Miranda* custody occurred between the two interrogations.
- The Maryland Court of Appeals reversed, holding *Edwards* protection did not end by passage of time and that return to general prison population was not a break in custody.

## Issues

1. Whether *Edwards v. Arizona*’s prohibition on police-initiated custodial interrogation after a suspect invokes the right to counsel terminates after a substantial break in *Miranda* custody.
2. Whether an incarcerated suspect’s return from interrogation to the general prison population, followed by a lapse exceeding two and a half years, constitutes such a break.

## Decision

- The Supreme Court reversed the Maryland Court of Appeals.
- The Court held that *Edwards* does not apply indefinitely; the presumption ends after a break in *Miranda* custody lasting more than 14 days.
- The Court held that Shatzer experienced a sufficient break in *Miranda* custody when he returned to the general prison population and remained there for years before reinterrogation.
- Because Shatzer received fresh *Miranda* warnings and waived his rights in 2006 after the break, *Edwards* did not require suppression of his statements.

## Legal Principles

- Under *Edwards*, once a suspect invokes the right to counsel during custodial interrogation, a subsequent police-initiated waiver is presumed involuntary while the suspect remains in uninterrupted *Miranda* custody.
- The *Edwards* presumption is a prophylactic rule aimed at preventing police badgering and preserving the suspect’s choice to deal with police only through counsel.
- The *Edwards* presumption terminates after a break in *Miranda* custody lasting more than 14 days, after which renewed police-initiated interrogation may proceed if *Miranda* warnings are given and a valid waiver is obtained.
- For incarcerated persons, release from interrogation back to ordinary prison life in the general population can constitute a break in *Miranda* custody because ordinary prison conditions differ from interrogation’s police-dominated setting.

## Conclusion

The Court held that *Edwards*’s bar on police-initiated interrogation after invocation of counsel ends after a 14-day break in *Miranda* custody, and that returning an inmate to the general prison population for more than that period permits later reinterrogation following fresh *Miranda* warnings and a valid waiver.


Maryland v. Shatzer, 559 U.S. 98 (2010)