Master Supreme Court held that a 14-day break in custody resets the Edwards bar and that returning an inmate to the general prison population constitutes a break in Miranda custody. with this comprehensive case brief.
Maryland v. Shatzer is a landmark criminal procedure decision clarifying the scope and duration of the Edwards v. Arizona protection that bars police-initiated interrogation after a suspect invokes the Miranda right to counsel. The Court established a clear, administrable rule: a break in custody of at least 14 days ends the Edwards presumption, allowing police to reapproach a suspect, re-administer Miranda warnings, and obtain a valid waiver. The decision also resolves a recurring question in prison settings, holding that returning an incarcerated suspect to the general prison population is a break in Miranda custody for Edwards purposes.
For law students and practitioners, Shatzer matters because it operationalizes the prophylactic nature of Miranda and Edwards with a bright-line temporal rule. It balances protection against coercive pressure with law enforcement needs, preventing the Edwards rule from becoming a perpetual bar for inmates while ensuring that suspects have a meaningful cooling-off period to consult counsel and reassume their baseline autonomy before renewed questioning.
559 U.S. 98 (2010)
While incarcerated on an unrelated conviction, Michael Shatzer was questioned in 2003 by a detective investigating new allegations of child sexual abuse. The detective administered Miranda warnings. Shatzer invoked his right to counsel, the interview immediately ended, and he was returned to the general prison population to resume his normal routine. The investigation was closed. Approximately two and a half years later, a different detective reopened the investigation and interviewed Shatzer at the prison. After being advised of his Miranda rights again, Shatzer waived them and made incriminating statements. Five days later, he underwent a polygraph examination and, after fresh Miranda warnings, gave additional inculpatory statements. Charged with sexual offenses, Shatzer moved to suppress the 2006 statements, arguing that under Edwards v. Arizona police could not initiate further interrogation once he had previously requested counsel. The trial court denied suppression. The Maryland Court of Appeals reversed, holding that because Shatzer remained incarcerated the Edwards bar persisted. The U.S. Supreme Court granted certiorari.
Does the Edwards v. Arizona rule, which bars police-initiated interrogation after a suspect invokes the Miranda right to counsel, continue indefinitely for an incarcerated suspect, or is it terminated by a break in custody—and if so, how long must the break be?
Under Edwards v. Arizona, once a suspect in Miranda custody invokes the right to counsel, law enforcement must cease interrogation until counsel is made available, unless the suspect initiates further communication. Because Edwards is a prophylactic safeguard, its protection terminates after a break in Miranda custody. A break in custody of at least 14 days suffices to dissipate the coercive pressures of custody and permits police to reapproach the suspect, administer fresh Miranda warnings, and seek a valid waiver. For an incarcerated person, returning to the general prison population after interrogation constitutes a break in Miranda custody for Edwards purposes.
A break in custody of 14 days ends the Edwards presumption. Returning an inmate to the general prison population is a break in Miranda custody. Because Shatzer experienced a break in custody exceeding 14 days—indeed, about two and a half years—Edwards did not bar the 2006 police-initiated interrogation, and his statements were admissible.
The Court emphasized that Edwards is a judicially crafted prophylactic designed to counteract the inherently compelling pressures of custodial interrogation and prevent badgering after a suspect has requested counsel. As a prophylactic, it may be tailored to its rationale and is not a constitutional mandate of indefinite duration. The coercion Edwards seeks to mitigate diminishes once a suspect is released from Miranda custody and returns to normal life, where he can consult advisors and is no longer isolated in a police-dominated environment. The Court held that returning an inmate to the general prison population qualifies as a break in Miranda custody. Ordinary prison life, though restrictive, is not the type of police-dominated, interrogation-focused environment that creates the Miranda coercion Edwards targets. Treating incarceration itself as continuous Miranda custody would transform Edwards into a de facto perpetual immunity from reapproach for all incarcerated persons who once invoked counsel, an outcome the Court found inconsistent with Miranda’s balance and with practical law enforcement. To provide clarity and administrability, the Court set a 14-day bright-line period as the minimum break required to terminate Edwards. Fourteen days gives a suspect time to get reacclimated to normal life (or routine prison life), consult counsel, family, or friends, and recover from any residual pressure of prior questioning. The Court rejected case-by-case approaches as unworkable and insufficiently protective. Applying these principles, the two-and-a-half-year lapse and Shatzer’s return to the general population were more than sufficient to reset Edwards. Because Shatzer received fresh Miranda warnings and validly waived his rights before speaking in 2006, suppression was unwarranted.
Shatzer establishes a clear 14-day break-in-custody rule that limits the duration of Edwards and brings predictability to interrogation practices. It also clarifies that incarceration alone is not continuous Miranda custody for Edwards purposes; returning to general population is a break that can reset the Edwards bar. For law students, the case illustrates how the Court calibrates prophylactic rules to their purposes, the interplay between Miranda, Edwards, and later cases like Minnick, and the preference for bright-line rules in criminal procedure when administrability and deterrence concerns are at stake.
Edwards v. Arizona bars police from reinitiating interrogation after a suspect in custody invokes the right to counsel, unless the suspect initiates further communication. Maryland v. Shatzer modifies the duration of that bar by holding that a break in custody of at least 14 days terminates Edwards, allowing police to reapproach with fresh Miranda warnings and seek a waiver.
No. Shatzer holds that returning an inmate to the general prison population after an interrogation is a break in Miranda custody for Edwards purposes. While certain prison questioning may still be custodial under Miranda, the baseline of ordinary prison life is not treated as continuous Miranda custody that indefinitely extends Edwards.
The Court selected 14 days as a clear, administrable minimum that allows the suspect to re-acclimate to normal conditions, consult with counsel, family, or friends, and dissipate any coercive pressure from prior interrogation. The Court favored a bright-line rule over case-specific balancing to ensure predictability and adequate protection.
No. Shatzer concerns the Fifth Amendment-based Miranda/Edwards protections during custodial interrogation. The Sixth Amendment right to counsel is offense-specific and attaches at or after initiation of formal adversary proceedings; its waiver and reinterrogation rules are governed by different precedents (e.g., Montejo v. Louisiana).
If police initiate interrogation within 14 days of the Edwards invocation, any purported waiver is presumed invalid and statements are generally inadmissible, unless the suspect himself initiated further communication and knowingly and intelligently waived the right to counsel under the Edwards/Minnick framework.
Edwards applies regardless of which officer or agency reinitiates questioning; the key is whether the suspect experienced a qualifying break in custody. After a 14-day break (or more), police—whether the same or different—may reapproach with fresh Miranda warnings and seek a valid waiver.
Maryland v. Shatzer provides a practical and principled limit to the Edwards rule by recognizing that the coercive pressures of custodial interrogation do not persist indefinitely. By deeming a return to the general prison population a break in Miranda custody and setting a 14-day reset period, the Court harmonized suspect protections with the realities of ongoing investigations.
For exam and practice, Shatzer is essential: identify the moment of Edwards invocation, determine whether there was a break in Miranda custody, and measure the time elapsed. If at least 14 days passed and fresh Miranda warnings were given before a knowing, intelligent, and voluntary waiver, a subsequent interrogation is not barred by Edwards.