Maryland v. Shatzer, No. 08–680, __ U.S. __ (Feb. 24, 2010)
Adopts a brightline rule that a fourteen-day break in Miranda custody ends the presumption of involuntariness established in Edwards v. Arizona for responses to police-initiated questioning after a subject has invoked the right to have Miranda counsel present during interrogation; a subject incarcerated for an unrelated crime is not in Miranda custody for purposes of this fourteen-day rule.