In 2003, Michael Blaine Shatzer Sr. was incarcerated in a Maryland facility for child sexual abuse. While detained he was questioned regarding a separate incident, the accused of sexual abuse against his son. When authorities attempted to question him on this accusation, Mr. Shatzer maintained his right to remain silent. Two and a half years later, in 2006 Shatzer was questioned again regarding sexual misconduct against his son. This time, Shatzer admitted to sexual deviance in the form of masturbation. As a result of this admission, Shatzer was found guilty of the crime.
The defendant petitioned the case to the Court of Appeals of Maryland, citing the evidenced used was inadmissible, a violation of the law, and unconstitutional. The defendant argued this violated 5th amendment and 14th amendment rights also observed under the Miranda law, Miranda v. Arizona (1966). Miranda provides that individuals are aware of their rights and discouraged from self-incrimination, (Maryland v Shatzer, 2010). In Edwards v. Arizona (1981), the courts recognize that “a valid waiver of that right cannot be established by showing only that he responded to further police-initiated custodial interrogation even if he has been advised of his rights” (Maryland v Shatzer, 2010). This specifically addresses individual in custody and continued questioning.
The Court of Appeals of Maryland reversed and remanded, (Supreme Court, 2010). Judges decided that two and a half years was not sufficient time to revoke Shatzer’s original waiver to remain silent. Furthermore, the court considered Shatzer’s continued incarceration. Shatzer did not undergo a break in custody and cannot be applied to his release “back into the general prison population between interrogations”, (Maryland v Shatzer, 2010). This identifies the evidence used to convict Shatzer as inadmissible observed in Edwards v Arizona. Although more than two years expired since his initial waiver, Shatzer did not instigate communication with authorities regarding the accusation nor provided counsel during integration (Maryland v Shatzer, 2013).
The Supreme Court, “reverse the judgment of the Court of Appeals of Maryland, and remand the case for further proceedings not inconsistent with this opinion”, (Maryland v Shatzer, 2010). The count found that two and a half years was sufficient lapse to interrogate the defendant regarding the matter. Edward v Arizona is a ruling of the court and not a constitutional right. Therefore Edwards should not be extended. The Miranda ruling ensures individuals are aware of their rights. The court then determined that two weeks must lapse before authorities can question an individual if Miranda rights are applied.
Maryland v Shatzer. (2010). Surpreme Court. (no. 08-680) 405 Ms. 585,954 A. 2d 1118 Reversed and Remanded. Opinion of the Court. Retrieved from: http://www.law.cornell.edu/supct/html/08-680.ZO.html
Maryland v Shatzer. (2013). Case Basics. Roxbury Correctional Instutute. The Oyez Project at IIT Chicago-Kent College of Law. 04 October 2013. <http://www.oyez.org/cases/2000-2009/2009/2009_08_680>.