Summary
U. S. Supreme Court case involving a habitual sex offender found guilty of molesting his 3-year-old son. In 2003, while Michael Shatzer was in prison for molesting another child, his son told a social worker about an incident involving oral sex with his father. When a police investigator met with Shatzer in prison to question him, Shatzer invoked his Miranda rights and refused to discuss the matter without an attorney present. Because the 3-year-old victim was the only witness, the case was closed. Three years later, when Shatzer's son, then six, was more capable of describing the incident, the case was reopened and another detective visited Shatzer in prison. This time Shatzer waived his Miranda rights and admitted that he had molested his child. Following his failure to suppress the confession, Shatzer was convicted. Maryland's highest court overturned the conviction on appeal, citing a Supreme Court holding in Edwards v. Arizona, which involved a second interrogation of a suspect the day after he had refused to answer questions. When the Supreme Court agreed to review that ruling, CJLF joined the case to argue that the Edwards decision did not apply because Shatzer was already a prison inmate with no expectation of being set free if he cooperated and because 2½ years had lapsed between the two interviews. The high court agreed. [CJLF brief in PDF.]
