Maryland v. Shatzer

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Maryland v. Shatzer
Seal of the United States Supreme Court.svg
Argued October 5, 2009
Decided February 24, 2010
Full case nameMaryland, Petitioner v. Michael Blaine Shatzer, Sr.
Citations559 U.S. 98 ( more )
130 S. Ct. 1213; 175 L. Ed. 2d 1045; 2010 U.S. LEXIS 1899
Case history
PriorDefendant convicted, No. 21–K–06–37799 (Cir. Ct. Washington Cty., Md., September 21, 2006); Court of Appeals of Maryland reversed and remanded, 405 Md., at 606–607, 954 A. 2d, at 1131; cert. granted, 555 U. S. ___ (2009). 405 Md. 585, 954 A. 2d 1118
Holding
Police may re-open questioning if there has been a two-week break in Miranda custody.
Court membership
Chief Justice
John Roberts
Associate Justices
John P. Stevens  · Antonin Scalia
Anthony Kennedy  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Samuel Alito  · Sonia Sotomayor
Case opinions
MajorityScalia, joined by Roberts, Kennedy, Ginsburg, Breyer, Alito, Sotomayor; Thomas (Part III)
ConcurrenceThomas (in part and in judgment)
ConcurrenceStevens (in judgment)

Maryland v. Shatzer, 559 U.S. 98 (2010), was a United States Supreme Court case in which the Court 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.

Contents

Background

In Miranda v. Arizona (1966), 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 police questioning must cease. Left unanswered was how long this protection applied—when could police resume questioning? [1]

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. [2]

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. [3] The state of Maryland petitioned the Supreme Court for a writ of certiorari, which was granted on January 26, 2009. [4]

Opinion

Justice Scalia 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. [5]

The court divided its opinion into four parts:

Part I reviewed the prior history of the case before the court.

Part II, the court explained that the Edwards rule, (which required police to cease questioning once a suspect had asked for an attorney) while not a constitutional guarantee itself, served as a "prophylactic" for a suspect's Fifth Amendment rights. 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." [6] 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." [7]

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. [8]

In Part IV, the court responded to claims made by Justice Stevens in his concurrence that the majority opinion underestimated the coercive effect of a police interrogator re-opening a line of questioning after a break in custody. [9]

Related Research Articles

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Miranda v. Arizona, 384 U.S. 436 (1966), was a landmark decision of the U.S. Supreme Court in which the Court ruled that the Fifth Amendment to the U.S. Constitution restricts prosecutors from using a person's statements made in response to interrogation in police custody as evidence at their trial unless they can show that the person was informed of the right to consult with an attorney before and during questioning, and of the right against self-incrimination before police questioning, and that the defendant not only understood these rights but also voluntarily waived them.

<span class="mw-page-title-main">Ernesto Miranda</span> American criminal and subject of a United States Supreme Court case

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Escobedo v. Illinois, 378 U.S. 478 (1964), was a United States Supreme Court case holding that criminal suspects have a right to counsel during police interrogations under the Sixth Amendment. The case was decided a year after the court had held in Gideon v. Wainwright that indigent criminal defendants have a right to be provided counsel at trial.

Danny Escobedo was a Chicago petitioner in the Supreme Court case of Escobedo v. Illinois, which established a criminal suspect's right to remain silent and to have an attorney present during questioning. This case was an important precedent to the famous Miranda v. Arizona decision.

Missouri v. Seibert, 542 U.S. 600 (2004), is a decision by the Supreme Court of the United States that struck down the police practice of first obtaining an inadmissible confession without giving Miranda warnings, then issuing the warnings, and then obtaining a second confession. Justice David Souter announced the judgment of the Court and wrote for a plurality of four justices that the second confession was admissible only if the intermediate Miranda warnings were "effective enough to accomplish their object." Justice Anthony Kennedy wrote in a concurring opinion that the second confession should be inadmissible only if "the two-step interrogation technique was used in a calculated way to undermine the Miranda warning."

McNeil v. Wisconsin, 501 U.S. 171 (1991), held that the right to counsel secured by the Sixth Amendment and the right to counsel protected by Miranda v. Arizona are separate and distinct, such that invoking one does not implicitly invoke the other.

Massiah v. United States, 377 U.S. 201 (1964), was a case in which the Supreme Court of the United States held that the Sixth Amendment to the United States Constitution prohibits the government from eliciting statements from the defendant about themselves after the point that the Sixth Amendment right to counsel attaches.

Oregon v. Bradshaw, 462 U.S. 1039 (1983), applied the rule first announced in Edwards v. Arizona (1981) and clarified the manner in which a suspect may waive his right under Miranda v. Arizona (1966) to have counsel present during interrogation by the police.

<span class="mw-page-title-main">Fifth Amendment to the United States Constitution</span> 1791 amendment enumerating due process rights

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Berkemer v. McCarty, 468 U.S. 420 (1984), is a decision of the United States Supreme Court that ruled that a person in police custody following a misdemeanor traffic offense was entitled to the protections of the Fifth Amendment pursuant to the decision in Miranda v. Arizona 384 U.S. 436 (1966). Previously, some courts had been applying Miranda only to serious offenses.

Michigan v. Jackson, 475 U.S. 625 (1986), was a case decided by the United States Supreme Court regarding the Sixth Amendment's right to counsel in a police interrogation. In a decision written by Justice Stevens, the Court held that once an accused individual has claimed a right to counsel at a plea hearing or other court proceeding, a waiver of that right during later police questioning would be invalid unless the accused individual initiated the communication.

Montejo v. Louisiana, 556 U.S. 778 (2009), is a 5–4 decision by the United States Supreme Court that overruled the Court's decision in Michigan v. Jackson. The case concerned the validity of a defendant's waiver of his right to counsel during a police interrogation. In reversing Jackson, the Court said such a waiver was valid.

Edwards v. Arizona, 451 U.S. 477 (1981), 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. Re-interrogation is only permissible once defendant's counsel has been made available to him, or he himself initiates further communication, exchanges, or conversations with the police. Statements obtained in violation of this rule are a violation of a defendant's Fifth Amendment rights.

Berghuis v. Thompkins, 560 U.S. 370 (2010), is a landmark decision by the Supreme Court of the United States in which the Court considered the position of a suspect who understands their right to remain silent under Miranda v. Arizona and is aware that they have the right to remain silent, but does not explicitly invoke or waive the right.

J.D.B. v. North Carolina, 564 U.S. 261 (2011), was a case in which the Supreme Court of the United States held that age and mental status is relevant when determining police custody for Miranda purposes, overturning its prior ruling from seven years before. J.D.B. was a 13-year-old student enrolled in special education classes whom police had suspected of committing two robberies. A police investigator visited J.D.B. at school, where he was interrogated by the investigator, a uniformed police officer, and school officials. J.D.B. subsequently confessed to his crimes and was convicted. J.D.B. was not given a Miranda warning during the interrogation, nor an opportunity to contact his legal guardian.

Yarborough v. Alvarado, 541 U.S. 652 (2004), is a United States Supreme Court case in which the Court declined to overturn a state court's conclusion that a minor was not in custody for Miranda purposes during his police interview. Michael Alvarado helped his friend Paul Soto steal a truck in Santa Fe Springs, California. The truck owner was killed by Soto during the robbery and Alvarado was convicted of second-degree murder for his role in the crime. The evidence for Alvarado's conviction was primarily based on statements given by Alvarado during a two-hour police interrogation that occurred when Alvarado's parents brought him to the police station. Alvarado was 17 years old and was not read his Miranda rights before questioning. During Alvarado's murder trial in a state court, motions to suppress the statements given by Alvarado were denied on the ground that Alvarado was not in police custody at the time of the interrogation and thus did not have to be read his Miranda rights. Alvarado appealed his conviction, claiming that the determination that he was not in custody was incorrect because the courts did not take his age into account.

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Florida v. Powell, 559 U.S. 50 (2010), was a case in which the Supreme Court of the United States ruled on the language requirements for Miranda warnings. In the case, a suspect was advised of his right to consult with an attorney before questioning, as well as his right to consult with an attorney at any time during questioning. However, he was not advised of his right to the physical presence of an attorney during questioning.

References

  1. Maryland v. Shatzer, 559 U.S. ___ (2010) (No. 08-680), p. 4-5. A previous case, McNeil v. Wisconsin , had addressed the break in custody in dicta but not as part of the decision. Maryland v. Shatzer, 559 U.S. ___ (2010) (No. 08-680), p. 6
  2. Maryland v. Shatzer, 559 U.S. ___ (2010) (No. 08-680), p. 2-3.
  3. Maryland v. Shatzer, 559 U.S. ___ (2010) (No. 08-680), p. 3-4.
  4. Supreme Court of the United States. "Docket: No. 08-680" . Retrieved 2010-05-02.
  5. Maryland v. Shatzer, 559 U.S. ___ (2010) (No. 08-680), p. 2.
  6. Maryland v. Shatzer, 559 U.S. ___ (2010) (No. 08-680), p. 4-11.
  7. Maryland v. Shatzer, 559 U.S. ___ (2010) (No. 08-680), p. 12-13.
  8. Maryland v. Shatzer, 559 U.S. ___ (2010) (No. 08-680), p. 14-16.
  9. Maryland v. Shatzer, 559 U.S. ___ (2010) (No. 08-680), p. 16-18.