Maryland v. Shatzer

In Maryland v. Shatzer, U.S. 130 S. Ct. 1213, 1217, 1223, 175 L. Ed. 2d 1045 (2010), the Supreme Court recently extended the Edwards rule to breaks in custody lasting less than fourteen days. The Court reasoned: The protections offered by Miranda, which we have deemed sufficient to ensure that the police respect the suspect's desire to have an attorney present the first time police interrogate him, adequately ensure that result when a suspect who initially requested counsel is reinterrogated after a break in custody that is of sufficient duration to dissipate its coercive effects. Shatzer, U.S. at, 130 S. Ct. at 1222. The Court found a fourteen-day period "provides plenty of time for the suspect to get reacclimated to his normal life, to consult with friends and counsel, and to shake off any residual coercive effects of his prior custody." Id. at, 130 S. Ct. at 1223.