Miranda rights

Corley v. United States

Issues

Whether federal law requires that a confession  taken  more than six hours after a defendant's arrest, and before the defendant appears before the magistrate judge, must be suppressed if there was unreasonable delay in bringing the defendant before the judge.

 

When Johnnie Corley was arrested for assaulting an officer and interrogated about the robbery of a credit union, he did not confess to a role in the robbery until more than six hours after his arrest. Moreover, Corley did not appear before a magistrate judge until the next day. After the District Court found Corley guilty, the Third Circuit affirmed. Corley is now appealing to the Supreme Court of the United States. His case will determine whether, if there was unreasonable delay in bringing a suspect before a magistrate judge, the suspect's confession is still valid. The Supreme Court's decision will affect suspects' rights and the procedure that police must follow during a confession.

 

    Questions as Framed for the Court by the Parties

    Whether 18 U.S.C. § 3501 - read together with Fed. R. Crim. P. Rule 5(a), McNabb v. United States, 318 U.S. 332 (1943), and Mallory v. United States, 354 U.S. 449 (1957) - requires that a confession taken more than six hours after arrest and before presentment be suppressed if there was unreasonable or unnecessary delay in bringing the defendant before the magistrate judge.

    Federal law enforcement officials identified Johnnie Corley as one of three men who robbed the Norsco Federal Credit Union in Norristown, Pennsylvania, on June 16, 2003. See U.S. v. Corley, 500 F.3d 210, 212 (3d Cir.

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    Maryland v. Blake

    Issues

    If one police officer violates a suspect's Fifth Amendment right to remain silent by making an inappropriate remark after the suspect has invoked that right, can the words and acts of another officer, and other circumstances, such as the passage of time, sufficiently repair the situation in order to allow the suspect to later waive his right to remain silent?

     

    When the Annapolis Police arrested Leeander Blake, he invoked his right to remain silent until granted access to an attorney. While Blake was still in custody, and after Blake had invoked his right to remain silent, an officer made an inappropriate remark to him. However, the officer leading the investigation swiftly rebuked this officer, in front of Blake, for his remark. Shortly thereafter, Blake made incriminating statements without an attorney that the State sought to use against him. Under Edwards v. Arizona, a suspect who has invoked his right to remain silent cannot later waive that right unless he initiates the conversation and does so knowingly and intelligently. The Court must decide whether the supervising officer's curative remarks in this case sufficiently restored Blake's rights prior to Blake's incriminating statements.

    Questions as Framed for the Court by the Parties

    When a police officer improperly communicates with a suspect after  invocation  of the suspect's right to counsel, does Edwards permit consideration of curative measures by the police, or other intervening circumstances, to conclude that a suspect later initiated communication with the police?

    On October 19, 2002 in Annapolis, Maryland, unknown assailants shot Straughan Lee Griffin in the head and stole his car; the assailants ran over his body as they fled. Blake v. Maryland, 381 Md. 218, 222 (2004).

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    Maryland v. Shatzer

    Issues

    Is a confession made by a criminal defendant more than two years and six months after invoking his or her Fifth Amendment right to counsel admissible in court?

     

    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.

    Questions as Framed for the Court by the Parties

    Is the Edwards v. Arizona prohibition against interrogation of a suspect who has invoked the Fifth Amendment right to counsel inapplicable if, after the suspect asks for counsel, there is a break in custody or a substantial lapse in time (more than two years and six months) before commencing reinterrogation pursuant to Miranda?

    In 2003, the Hagerstown Police Department (“Police Department”) began investigating Respondent, Michael Shatzer (“Shatzer”), for alleged sexual abuse of his three-year-old son. See Shatzer v. Maryland, 954 A.2d 1118, 1120 (Md. Ct. App.

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