## Facts

- Maine drug agents investigated suspected importation and trafficking of methamphetamine and other drugs from Canada and developed information linking Scott E. Knowlton to the activity.
- An MDEA agent asked Knowlton at his workplace to come to the police department; Knowlton went voluntarily and unrestrained.
- In an interview room, the agent confronted Knowlton with the investigation and questioned him about alleged trafficking.
- Knowlton became upset and requested an attorney; the agent immediately ended the interview and placed Knowlton under arrest.
- After the arrest, the agent permitted Knowlton to speak with family members and then transported him to a jail about an hour away; Knowlton remained in continuous custody.
- During transport, Knowlton told the agent he wanted to cooperate but was scared.
- Near the jail, the agent stated that if Knowlton wanted to talk again after consulting an attorney, he should contact the agent; Knowlton then agreed to talk without an attorney.
- The agent drove Knowlton to an MDEA office, presented a written waiver-of-rights form, and Knowlton signed it and made incriminating statements.
- Approximately five hours elapsed between Knowlton’s request for counsel and his written waiver, and he did not consult an attorney during that time.
- Knowlton was indicted for aggravated trafficking, unlawful trafficking, and illegal importation of scheduled drugs; the trial court suppressed the later statements, and the State appealed.

## Issues

1. After a suspect in continuous custody invokes the right to counsel, what standard governs whether later statements are admissible when the suspect later speaks and signs a waiver?
2. Did the trial court err by applying Shatzer’s fourteen-day break-in-custody rule, rather than the Edwards/Bradshaw framework, to evaluate whether Knowlton reinitiated communication and validly waived counsel?

## Decision

- The Supreme Judicial Court of Maine vacated the suppression order and remanded.
- The court held the trial court used the wrong analytical framework by treating Shatzer’s fourteen-day rule as controlling despite the absence of any break in custody.
- The court directed the trial court to reconsider the existing record under Edwards and Bradshaw, focusing on whether Knowlton initiated further communication and whether any waiver was knowing, intelligent, and voluntary.
- The court did not decide the ultimate admissibility of the statements and indicated the matter could be resolved on the existing record.

## Legal Principles

- Once a suspect invokes the right to counsel during custodial interrogation, law enforcement must cease questioning until counsel is made available, unless the suspect initiates further communication with police.
- When custody is continuous, the governing test for post-invocation statements is Edwards v. Arizona and Oregon v. Bradshaw, not Shatzer’s fourteen-day rule.
- Shatzer’s fourteen-day minimum waiting period applies when police seek to reinitiate interrogation after a break in custody following invocation of counsel.
- On a challenge to voluntariness, the State bears the burden to prove beyond a reasonable doubt that the suspect’s decision to speak and any waiver of rights were voluntary, knowing, and intelligent under the totality of the circumstances.

## Conclusion

The court clarified that where a suspect remains in uninterrupted custody after requesting counsel, suppression turns on whether the suspect initiated further discussion and then validly waived the right to counsel under Edwards and Bradshaw; Shatzer’s fourteen-day break-in-custody rule does not control absent a break in custody.


State v. Knowlton, 34 A.3d 1139 (Me. 2012)