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Court Clarifies "Break-in-custody" Exception

The Court's handed down Maryland v. Shatzer, No. 08-680, which concerned a sexual child abuse prosecution in which a state court of appeals reversed defendant's conviction on Miranda grounds. The Supreme Court granted the state's certiorari petition.

As the Court wrote:  "When, unlike what happened in these three cases, a suspect has been released from his pretrial custody and has returned to his normal life for some time before the later attempted interrogation, there is little reason to think that his change of heart regarding interrogation without counsel has been coerced."

The Supreme Court reversed, holding that defendant experienced a break in Miranda custody lasting more than two weeks between first and second attempts at interrogation, and thus Edwards did not mandate suppression of defendant's statements during the second interrogation.

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