559 U.S. 98 (2010)
Maryland v. Shatzer is a cornerstone Miranda decision that answers a question left open by Edwards v.
Does a break in Miranda custody end the Edwards v. Arizona prohibition on police-initiated interrogation following a suspect's invocation of the right to counsel, and if so, does returning an inmate to the general prison population constitute such a break and for how long must that break last?
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 and waives his rights. Maryland v. Shatzer clarifies and limits Edwards by holding that a break in Miranda custody lasting at least 14 days ends the Edwards presumption, allowing police to reinitiate questioning after administering fresh Miranda warnings and obtaining a valid waiver. Returning a confined defendant to the general prison population constitutes a break in Miranda custody for Edwards purposes.
Yes. A break in Miranda custody ends Edwards, and a period of at least 14 days is sufficient to dissipate the coercive pressures that Edwards addresses. Returning an inmate to the general prison population qualifies as a break in custody. Therefore, the 2006 interrogation of Shatzer—occurring more than two years after his 2003 invocation—did not violate Edwards. The Supreme Court reversed the Maryland Court of Appeals and remanded.
Shatzer fundamentally reshapes the Edwards framework by adding a clear endpoint: after a 14-day break in Miranda custody, police may reinitiate interrogation with fresh warnings. It also clarifies that incarceration does not automatically equal Miranda custody; returning a prisoner to the general population is a sufficient break for Edwards purposes. For law students, the case is essential for exam analysis of post-invocation interrogations, the scope of Miranda custody, and the interaction between prophylactic rules and constitutional protections. It supplies a bright-line doctrine that often decides suppression motions in practice.