In the case of Maryland v. Michael Blaine Shatzer, Sr., the U.S Supreme Court was tasked with determining whether a break in custody could allow for re-interrogation after an individual has invoked their Miranda rights. In 2003, Shatzer was imprisoned for a separate crime when police attempted to question him about allegations that he sexually abused his son. He declined to speak without an attorney present and the investigation ceased. Nearly three years later, another officer reopened the case and interrogated Shatzer who waived his rights and made incriminating statements leading to conviction on sexual child abuse charges. Shatzer appealed arguing that Edwards v Arizona (1981) prohibited further interrogation after requesting counsel unless initiated by defendant himself which wasn't followed here as there was no break in 'custody'. The court ruled against him stating that being released back into general prison population constituted a break in custody allowing renewed attempts at interrogation if sufficient time had passed - determined as 14 days or more.

In the dissenting opinion for Maryland v. Shatzer, Justice Stevens argued that the majority's decision to create a 14-day rule was arbitrary and unsupported by empirical evidence or logical reasoning. He contended that there is no reason to believe that after two weeks in prison, an inmate would feel less coerced into waiving his Miranda rights than he might have felt immediately after arrest. Furthermore, he criticized the majority's reliance on Edwards v. Arizona as precedent for their ruling because it did not involve a similar situation of re-interrogation after a significant lapse of time. Instead of creating an arbitrary time limit, Justice Stevens suggested that courts should consider all relevant circumstances when determining whether a suspect has been subjected to improper coercion during police questioning.