Maryland v. Shatzer

Background

A man who was already serving a prison sentence was questioned in 2003 about allegations of sexually abusing his young son. During that visit he said he would not talk without a lawyer and the interview stopped. He returned to the general prison population and the investigation was closed. More than two years later detectives re-opened the inquiry, read him his rights, and obtained statements in 2006 after he waived counsel.

Reasoning

The Court examined a rule from prior cases that treats a suspect’s request for counsel as creating a presumption that later police-initiated questioning will be involuntary. The Justices said that presumption rests on the special coercion of uninterrupted investigative custody. If a suspect is released and returns to normal life for a sufficient time, that coercion is much less likely. The Court therefore held that a break in custody ends the presumption and chose 14 days as the clear time period after which reinterrogation may proceed with a valid Miranda waiver.

Real world impact

Because the man had been back in the general prison population for more than 14 days, the Court ruled his 2006 statements were not automatically suppressed under that presumption. The decision treats lawful imprisonment after conviction as a break in the special kind of custody that triggers the extra protection, and gives police and courts a bright-line two-week rule to apply going forward.

Dissents or concurrances

Two Justices agreed the 2006 statements could be used but criticized or limited the new 14-day bright line. Another Justice agreed the break in prison custody mattered but questioned imposing a fixed time period for all cases.