In Edwards v. Arizona, the Supreme Court further clarified that once a suspect had invoked their right to have an attorney police questioning must cease.

[1] Michael Shatzer, the respondent in the case, was an inmate in the Maryland penal system, serving time for child sexual abuse.

The court justified this period by noting that 14 days "provides plenty of time for the suspect to get reacclimated to his normal life, to consult with friends and counsel, and to shake off any residual coercive effects of his prior custody.

"[7] In Part III, the court considered the specific facts of the case: under the newly qualified standards, did the three years between the two interviews, during which Shatzer was incarcerated, constitute a "break in custody"?

[8] In Part IV, the court responded to claims made by Justice Stevens in his concurrence that the majority opinion underestimated the coercive effect of a police interrogator re-opening a line of questioning after a break in custody.