State v. Knowlton
Annotate this CaseDefendant was indicted for aggravated trafficking of scheduled drugs, unlawful trafficking in scheduled drugs, and illegal importation of scheduled drugs. Defendant moved to suppress incriminating statements he made to a Maine Drug Enforcement Agency (MDEA) agent while in the agent's custody and after Defendant had invoked his right to counsel in violation of the Fifth Amendment. The superior court granted Defendant's motion after applying Maryland v. Shatzer, concluding that the State had failed to prove that 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, far less than the fourteen-day standard required by Shatzer. The Supreme Court vacated the superior court, holding that the court erred by evaluating the evidence and rendering its findings through the lens of the Shatzer fourteen-day standard and should have employed the analytical framework advanced in Edwards v. Arizona and Oregon v. Bradshaw in determining whether Defendant voluntarily reinitiated interrogation. Remanded for the court to reconsider the evidentiary record and to apply the Edwards and Bradshaw standards.
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