Oral argument: October 5, 2009
Appealed from: Court of Appeals of Maryland (Aug. 26, 2008)
FIFTH AMENDMENT, MIRANDA RIGHTS, POLICE INTERROGATION, SELF-INCRIMINATION
In 2003, Michael Shatzer (“Shatzer”), an inmate at the Maryland Correctional Institution, invoked his Miranda rights, refusing to speak about alleged sexual child abuse without an attorney present. The investigation into Shatzer’s alleged sexual child abuse was closed later that year. In 2006, upon further evidence, the police opened a new investigation on the same matter and re-interrogated Shatzer, who had remained incarcerated for an unrelated offense during the entire interval. Shatzer waived his Miranda rights and made certain admissions. At trial, Shatzer moved to suppress the statements he made in 2006, arguing that the police’s re-interrogation violated the Supreme Court’s decision in Edwards v. Arizona, which held that, once a suspect requests counsel, the police and/or prosecutor may not subject that suspect to further interrogations until counsel is made available. Maryland argues that this presumption does not apply here due to (1) a break in police custody and (2) a substantial passage of time between Shatzer’s request for counsel and the subsequent interrogation. The Court of Appeals of Maryland agreed with Shatzer, holding that the Circuit Court for Washington County erred by admitting Shatzer’s statements. The Supreme Court’s decision will likely impact the manner in which the police and prosecutors approach and interview suspects who have invoked their right to counsel.