Maryland v. Shatzer, 559 U.S. 98 (2010)
FACTS: In August of 2003 Detective Shane Blankenship, a social worker, was assigned to investigate and interview Michael Shatzer about claims that Shatzer had sexually abused his three year old son. At the time of the investigation Shatzer was incarcerated at Maryland Correctional Institution-Hagerstown for an unrelated child-sexual abuse offense. Before asking Shatzer any questions, Detective Blankenship informed Shatzer of his rights, Shatzer then obtained a written waiver of those rights. Blankenship proceeded to end the interview, release Shatzer back into the general prison population, and end the investigation. After two years and six months, Dectective Hoover reopened the investigation, interviewed Shatzer's son who was now eight years old, who could now describe the incident in more detail. In March of 2006, Hoover went to Roxbury Correctional Institute to interview Shatzer about sexually abusing his son. After approximately 30 minutes of interviewing, Shatzer agreed to take a polygraph; in which he failed. At no point during this second interview did Shatzer request to speak to a lawyer or refuse to answer Hoover's questions without a lawyer present. After incriminating himself, Shatzer was charged with second-degree sexual offense, sexual child abuse, second-degree assault and contributing to conditions rending a child in need of assistance. In court, Shatzer moved to suppress his March 2006 statements in regards to Edwards v. Arizona, 451 U.S. 477 (1981). The trail court denied his motion. The Court of Criminal Appeals of Maryland reversed the trail courts decision stating that release of Shatzer back into the general prison population did not constitute a break in custody.
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