People v. BridgefordAnnotate this Case
Defendant was convicted of two counts of murder in the first degree (counts 1 and 2), as well as one count of active participation in a criminal street gang (count 3). In the published portion of the opinion, the court addressed defendant's argument that the trial court prejudicially erred when it failed to apply Maryland v. Shatzer, which held that law enforcement must wait 14 days before it may resume questioning (absent initiation by the suspect or with the presence of counsel) after a suspect has invoked his or her right to counsel and is released from custody. The court concluded that the trial court erred in not applying Shatzer because the requisite 14-day break-in-custody did not occur in defendant’s case, and the error was prejudicial. Accordingly, the court reversed the convictions and remanded for a new trial.