Sunday, November 17, 2013

State v. Knowlton case brief

State v. Knowlton case brief summary
34 A.3d 1139 (2012)

Defendant, charged with drug trafficking, moved to suppress statements he made to an agent of the Maine Drug Enforcement Agency. The Superior Court, Aroostook County, Maine, granted the motion; the State appealed.

Shortly after the agent read defendant his Miranda rights at a police station, defendant became upset and asked to speak to an attorney. The agent terminated the interview, arrested defendant, and told him that he could speak with police if he wanted to after he had spoken with an attorney. While the agent was driving defendant to the jail, defendant, after talking to his mother on a cell phone, told the agent that he had changed his mind and would speak to the agent without an attorney present. The trial court held that the State failed to prove defendant's waiver of his right to counsel was voluntary because the agent had resumed his questioning of defendant just a few hours after defendant had invoked his right to counsel, while Maryland v. Shatzer required a minimum 14-day waiting period between the release from custody of a suspect who invoked the right to counsel and the reinitiation of police interrogation.


  • The high court held that as there had been no break in custody, Shatzer was inapplicable. 
  • The trial court erred by failing to applying the holdings of Edwards v. Arizona and Oregon Bradshaw to determine whether defendant voluntarily initiated the interrogation.

The suppression order was vacated and the case was remanded for further proceedings in which the trial court was to reconsider the evidentiary record and to apply the Edwards and Bradshaw standards.

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