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Decision rejects invalid confession claim
The United States Supreme Court has reinstated the conviction of a Maryland child molester who claimed that his confession to police detectives was improperly introduced at trial. At issue in Maryland v. Shatzer was whether a confession made by a prison inmate, 2½ years after he refused to talk to investigators, violated precedent which prohibits police from badgering a suspect. A 2008 Maryland high court ruling concluded that the defendant’s rights had been violated, invalidating his conviction.
The California-based Criminal Justice Legal Foundation had joined the case to argue that the Maryland court ruling misinterpreted the Supreme Court’s 1981 decision in Edwards v. Arizona in order to reach its conclusion. “In today’s decision, the Supreme Court distinguished the circumstances in Edwards—where police held a suspect in jail overnight after he asked for an attorney and then questioned him again—from this case, where a detective interviewed Shatzer, as a prison inmate, 2½ years after he was initially questioned,” said the Foundation Attorney Lauren Altdoerffer.
The opinion by Justice Antonin Scalia noted the difference in potential for coercion between a person arrested by the same police who are questioning him and a sentenced prison inmate who knows that the police have no control over when he will be released. “Without minimizing the harsh realities of incarceration, we think lawful imposed upon conviction of a crime does not create the coercive pressures identified in Miranda.”
The case involves the conviction of a habitual sex offender who confessed to molesting his three-year-old son.
In August 2003, the victim described an incident to a social worker involving oral sex with his father. After she reported the conversation to the police, a detective interviewed the child. A few days later, the detective met with the boy’s father, Michael Shatzer, who was in prison for sexually abusing another child. The detective told Shatzer that he was a police officer and read him his Miranda rights, which Shatzer invoked. Shatzer refused to give a statement or answer any questions about the abuse of his son without a lawyer present. At that point, the detective told Shatzer to contact him when he had obtained an attorney and the interview ended. Because the three-year-old child was the only witness, the case was closed.
Three years later, after the victim, at age six, was better able to discuss the incident, the case was re-opened. In March 2006, a different detective, accompanied by the social worker, visited the prison to interview Shatzer. This time, after receiving his Miranda rights, he agreed to discuss the case. Shatzer initially denied abusing his son, but agreed to take a polygraph test. Later, after again receiving a Miranda warning, Shatzer broke down during the polygraph test, admitted the abuse, and claimed, “I didn’t force him.”
Prior to trial, Shatzer sought to exclude his incriminating statements, arguing that his request for an attorney years earlier prevented the use of the statements he made during the polygraph examination. The trial court denied his motion, citing the length of time between the interviews, the fact that he was in prison for the entire period, and his waiver of Miranda rights prior to his confession. Shatzer was convicted for the abuse and received an additional 15 years in prison.
In August 2008, the Maryland Court of Appeals (the high court in Maryland) overturned the conviction, ruling that the confession was taken in violation of Edwards v. Arizona, a 1981 Supreme Court decision barring police from initiating a second interview with a suspect held in jail overnight after he asked for an attorney.
When the Supreme Court agreed to hear the Maryland Attorney General’s appeal of that ruling, CJLF joined the case. The Foundation encouraged a decision to overturn the lower court’s ruling and reinstate Shatzer’s conviction. CJLF argued that the Maryland court incorrectly extended the prohibition against badgering announced in Edwards.
“The 2½-year lapse of time, Shatzer’s status as a prison inmate under a fixed sentence, and the fact that he could not expect release in return for his cooperation, made this case different,” said Altdoerffer. “The Court recognized that there was no reason to presume he was badgered into waiving his rights.”