In Maryland v. Shatzer, the Court announced a break-in- custody exception to the Edwards rule. 559 U.S. at 104-05. The Supreme Court held that Edwards did not mandate suppression of Shatzer’s incriminating statements because, after his first interrogation, Shatzer experienced a break in Miranda custody by returning to the general prison population and because the second round of interrogations occurred more than two-and-a-half years later. Id. at 114, 116-17. The Court maintained that a break in custody means different things for pretrial detainees and prison inmates. Id. at 106-07, 112-14. The Court concluded that “an extension of Edwards is not justified when a suspect who initially requested counsel is reinterrogated after a break in custody that is of sufficient duration to dissipate its coercive effects.” Id. at 109. In that circumstance, the fresh administration of Miranda warnings when the suspect is reinterrogated is “deemed sufficient” to protect his right to counsel. Ibid. A break in custody of fourteen days is sufficient “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.” Id. at 110.
A common misconception about Miranda warnings is that a conviction can not be sustained in a case in which they are not read to an arrestee. Miranda violations lead to the suppression of statements and evidence derived from those statements. Miranda violations do not lead to the suppression of evidence derived from independent sources.