Maryland v. Michael Blaine Shatzer, Sr.
USSC Case No. 08-680.
Oral Argument Date: Oct 5 2009
In the groundbreaking case of Miranda v. Arizona, the United States Supreme Court held that police officers must inform suspects of their right to remain silent, to consult with an attorney, to have an attorney present during questioning, and to have an attorney appointed if they cannot afford one. The Miranda opinion also noted that “[i]f the individual states that he wants an attorney, the interrogation must cease until an attorney is present.”
In the subsequent case of Edwards v. Arizona, the Supreme Court addressed a cognate question: What happens when a police officer reads a suspect a Miranda warning, but still asks questions after the suspect invokes the right to counsel? In Edwards, the Court held that statements made in response to such questioning are inadmissible at trial.
This fall, the Supreme Court will revisit the Miranda-Edwards line of case in Maryland v. Shatzer. Mr. Shatzer, the respondent in this case, was serving a prison sentence on an unrelated crime when a detective first interviewed him. When the detective read Mr. Shatzer his Miranda rights, Mr. Shatzer responded that he wanted an attorney present while the detective asked him questions. The detective wrote in his report, “When I attempted to again initiate the interview, he told me that he would not talk about this case without having an attorney present.” The detective then terminated the interview and closed the case. Two years and seven months later, though, a different detective conducted a follow-up investigation. That detective read Mr. Shatzer his Miranda rights and then — without allowing Mr. Shatzer any access to an attorney — interrogated him. Mr. Shatzer then confessed that he had committed a crime.
At trial, Mr. Shatzer argued that his confession was inadmissible, because the second detective obtained it in violation of Edwards. But in Edwards, only a day had elapsed between the suspect’s invocation of the right to counsel and the second interrogation. In contrast, two years and seven months had elapsed between Mr. Shatzer’s invocation of the right to counsel and the second interrogation. Moreover, while the suspect in Edwards was in continuous police custody between the first and second interrogation, Mr. Shatzer was not. Mr. Shatzer, though, was in prison for that entire period. (more…)