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Alani Gauthier

Mr. Williams
H American Literature
14 April 2015
Maryland v. Shatzer
On February 24, 2010, the Supreme Court decided Maryland v. Shatzer, holding the rule
of Edwards v. Arizona. The rule states that a waiver of Miranda rights by a suspect who
previously asserted those rights but remains in custody is involuntary. The rule no longer applies
once the suspect has been released from interrogative custody for at least fourteen days.
In August of 2003, a detective from Hagerstown, MD Police Department interviewed
Michael Blain Shatzer regarding some allegations that he had sexually abused his three year old
child. After Shatzer invoked his Fifth Amendment rights to counsel and to remain silent, the
interview was terminated. The investigation was closed, but only to be reopened in January of
2006. The case would be reopened on the prompting of Mrs. Shatzer recognizing her child could
make more specific allegations about Shatzers alleged sexual abuse. After all that, another
detective interviewed Shatzer in March of 2006. The detective was aware that he was under
investigation, but was not aware that Shatzer had previously invoked his Fifth Amendment rights
to counsel and to remain silent. At this particular interview, Mr. Shatzer was advised of his Fifth
Amendment rights, which he waived, and then confessed to specific incidents of sexual abuse
involving his child.

Before his trial, Mr. Shatzer tried arguing that his 2003 invocation of his Fifth
Amendment rights was still applicable even after he confessed in 2006. Edwards v. Arizona
rendered the confession inadmissible, not valid. The motion was denied and a Maryland trial
court convicted him of sexual child abuse. The court of Appeals of Maryland reversed, holding
that the protections of Edwards applies for an inmate who has been continually incarcerated and
had previously invoked his Fifth Amendment rights, until either counsel is made available or the
inmate initiates further conversation with police. Under all those circumstances, Mr. Shatzers
confession was inadmissible.
I ask myself why I was drawn to this court case and if I answer honestly, it is because it
was the first one to pop up. I can also say that after reading just a small portion, I was intrigued
and had to read more. The reason behind the court case is what really sparked my interest. I love
children, so when I glanced across the line sexually abused child it was over. This case came
off a little mind blowing because I did not know the courts could reverse a decision already
decided. I somewhat agree with the decision, but then again I do not. I agree with the Edwards
rule about the fourteen days I enough time to get back with life. Fourteen days is like one
hundred days to someone who has been incarcerated and there is no telling what thoughts came
to mind when the person was released. Because Michael was released for fourteen days, his
confessions were inadmissible and that is absurd. I feel like the fourteen days has nothing to do
with the confession. A confession is a confession and he made several not just one. Yea, Shatzer
was released for two weeks, but that does not make a confession invalid. I doubt somebody held
a gun to his head while he was out and told him to confess or else. I also understand that an
officer or somebody of higher power could have forced him to confess or something, but because
there is no evidence of facts behind that, I will stick with my opinion. With that being said, the

confession should not have been invalid. At the end of the day, nobody can make another person
confess to something they did not really do unless their life depends on it and I just do not
believe that is what happened. Overall, my heart sincerely goes out to the child in this situation.

Works Cited
Maryland v. Shatzer. Oyez Incorporation, 2005. Web. 30 March 2015.
Oort, Van. Supreme Court Decides Maryland v. Shatzer. Faegre Baker Daniels
LLP, 2000. Web. 23 March 2015.