Maryland v. Shatzer, 559 U.S. 98 (Feb. 24, 2010)

The Court held that a 2½ year break in custody ended the presumption of involuntariness established in Edwards v. Arizona, 451 U.S. 477 (1981) (when a defendant invokes the right to have counsel present during a custodial interrogation, a valid waiver of that right cannot be established by showing that the defendant responded to further police-initiated custodial interrogation even if the defendant has been advised of his Miranda rights; the defendant is not subject to further interrogation until counsel has been provided or the defendant initiates further communications with the police). The defendant was initially interrogated about a sexual assault while in prison serving time for an unrelated crime. After Miranda rights were given, he declined to be interviewed without counsel, the interview ended, and the defendant was released back into the prison’s general population. 2½ years later another officer interviewed the defendant in prison about the same sexual assault. After the officer read the defendant his Miranda rights, the defendant waived those rights in writing and made incriminating statements. At trial, the defendant unsuccessfully tried to suppress his statements pursuant to Edwards. The Court concluded: “The protections offered by Miranda, which we have deemed sufficient to ensure that the police respect the suspect’s desire to have an attorney present the first time police interrogate him, adequately ensure that result when a suspect who initially requested counsel is reinterrogated after a break in custody that is of sufficient duration to dissipate its coercive effects.” The Court went on to set a 14-day break in custody as the bright line rule for when the Edwards protection terminates. It also concluded that the defendant’s release back into the general prison population to continue serving a sentence for an unrelated conviction constituted a break in Miranda custody.