Cornell University Law School. For more information about the Maryland v. Shatzer decision and its impact on Miranda Rights, please contact Tricia Hynes. American Government [ABC-CLIO].

Then, an indictment for a court order would be placed to get a second DNA sample to use for the rape case.

Shatzer invoked his right to counsel, ending the interrogation, and the investigation was subsequently closed. MARYLAND v .

Written and curated by real attorneys at Quimbee. SHATZER certiorari to the court of appeals of maryland No.

Jun 27, 1990.

The defendant argued this violated 5th amendment and 14th amendment rights also observed under the Miranda law, Miranda v. Arizona (1966).

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 justices maintained that "categorically" and "without exception," "The Fourth Amendment forbids searching a person for evidence of a crime when there is no basis for believing the person is guilty of the crime or is in possession of incriminating evidence.

While detained he was questioned regarding a separate incident, the accused of sexual abuse against his son. Surpreme Court.

Previous Next. At the conclusion of this case, the Supreme Court ruled in favor of Maryland in that there is no real difference between "the practice of how DNA samples are used, and fingerprints, other than the unparalleled accuracy DNA provides." MARYLAND v.SHATZER(2010) No. Therefore Edwards should not be extended.
08-680, the Court will consider whether Edwards continues to prohibit interrogation when nearly three years has lapsed since the right to counsel was asserted and the suspect has remained incarcerated throughout that time for an unrelated crime. . MARYLAND v. SHATZER CERTIORARI TO THE COURT OF APPEALS OF MARYLAND No. The court then determined that two weeks must lapse before authorities can question an individual if Miranda rights are applied.

Finally, Shatzer argues that even if the Court were to recognize a “break in custody” exception to Edwards, such an exception would not apply to him because he was continuously in custody. 89-478 . No. American Bar Association: Criminal Justice Section (2013): p.2.

Turning to the broader implications of the Court’s ruling, Shatzer dismisses the State’s argument that applying Edwards indefinitely will hamper legitimate law enforcement as overstated.

The majority balanced state interests relating to detaining and charging arrestees against the affected individuals' interests in their bodily integrity and informational privacy. 08-680 Argued: October 5, 2009 Decided: February 24, 2010.

State of Maryland Government. Awarded the Sigma Delta Chi deadline reporting award for online coverage of the Affordable Care Act decision.

It can then be used to match convicts with other dangerous crimes, giving solace to families and protecting society. [14], Genetic and law enforcement technology used. The decision below should also be reversed, the State asserts, because the substantial lapse in time between interrogations further eliminated any coercive environment created by custodial interrogation.

Furthermore, the court considered Shatzer’s continued incarceration. [5], The dissent also warned that "because of today's decision, your DNA can be taken and entered into a national database if you are ever arrested, rightly or wrongly, and for whatever reason. On February 24, 2010, the U.S. Supreme Court came to a decision that will have long-lasting implications on police policy with respect to Miranda warnings.

shall be compelled in any criminal case to be a witness against himself.”  Miranda protects this right in the context of custodial interrogation by requiring the police to inform suspects of their right to counsel. After the Baltimore County Circuit Court ruled to suppress the evidence against Wilson, Maryland appealed to the Maryland Court of Special Appeals - which affirmed. Enter your email address to follow this blog and receive notifications of new posts by email. Did the closed-circuit testimony violate the Confrontation Clause of the Sixth Amendment?

In the State’s view, the protections provided by Edwards should be limited to the period in which the suspect is being held by police for questioning. DNA samples are also destroyed if "a criminal action begun against the individual... does not result in a conviction,... the conviction is finally reversed or vacated and no new trial is permitted "or "the individual is granted an unconditional pardon. Once taken, a DNA sample may not be processed or placed in a database before the individual is arraigned (unless the individual consents). Because he was not in police custody for questioning, he could not have continuously been subject to the coercive pressures of custodial interrogation against which Edwards is intended to protect.

Prior to Shatzer, the Edwards rule provided that a suspect who invokes his right to counsel may not be further questioned until either his or her counsel has been made available or until the suspect further initiates exchanges with the police. In Maryland v.King, 569 U.S. 435 (2013), the United States Supreme Court decided that a cheek swab of an arrestee's DNA is comparable to fingerprinting and therefore, a legal police booking procedure that is reasonable under the Fourth Amendment.. The State appealed to the Supreme Court, which reversed the decision. The Maryland Court of Appeals then reversed the original ruling, agreeing that the DNA sampling was a violation of the Fourth Amendment and could not be used as evidence.

On February 24, 2010, the U.S. Supreme Court came to a decision that will have long-lasting implications on police policy with respect to Miranda warnings. The case deals with the issue of consent, because King did not give consent to a cheek swab that led to his DNA being entered into the Maryland CODIS database. Here, because over two-and-a-half years had passed between interrogations and incarceration for an unrelated crime does not constitute “custody” for Miranda purposes, Edwards no longer applied.

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 decision was close, 5-4 in favor of Maryland. Change ), You are commenting using your Facebook account. Roxbury Correctional Instutute.

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).

Maryland law defines a crime of violence to include murder, rape, first-degree assault, kidnaping, arson, sexual assault, and a variety of other serious crimes. Symposia on rulings from October Term 2019.

The judge and jury also viewed the testimony in the courtroom.

2d 1118 Reversed and Remanded.


Nor, Shatzer argues, should the Court recognize any exception to Edwards based on the lapse of time since the initial interrogation. All felonies and some misdemeanors would result in that the suspect DNA is entered into the State CODIS (Combined DNA Index System) database. Regardless of how the evidence was obtained, King was considered a danger to society because of his association with a prior violent crime. Syllabus ; View Case ; Petitioner Maryland . They also echo Maryland’s arguments that serving a prison sentence constitutes a break in custody, as does a two-and-a-half-year lapse in time between interrogations, and that enforcing Edwards indefinitely would create significant obstacles to law enforcement.

A DNA sample offers more insight than a simple fingerprint, aiding the police and protecting the arrestee from being wrongly convicted. At issue was if a break in one’s custodial state occurs after the individual has invoked his right to counsel, when, if at all, may police resume interrogating the suspect and not violate his or her right to counsel? He explains that preserving the scope of Edwards will not result in the exclusion of all evidence arising from reinterrogation:  to the contrary, statements by suspects can be used under a variety of circumstances, such as when counsel is present. 6 Nov. 2015.

The Miranda ruling ensures individuals are aware of their rights. Edwards v. Arizona, 451 U.S. 477, 101 S.Ct. This time, Shatzer admitted to sexual deviance in the form of masturbation. The child testified outside the courtroom while Mrs. Craig, through electronic communication with her lawyer, could make objections.

04 October 2013.

Sorry, your blog cannot share posts by email. The amici ask the Court to balance the goals of Edwards with state law enforcement interests and hold that Edwards terminates when there is a break in custody. A “break in custody” exception would also create perverse incentives for the police to either ignore requests for counsel or to release and re-arrest a suspect in the hope that he will change his mind and waive his Miranda rights. [9] Instead of obtaining a warrant or tying the DNA swabbing to an individualized suspicion, taking DNA soon after an arrest is justified based on reasonableness by weighing "the promotion of legitimate governmental interests" against "the degree to which [the search] intrudes upon an individual's privacy" (133 S.Ct. After Shatzer’s son was able to provide new evidence which led to the subsequent interviews, Shatzer admitted the abuse.


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