State of Arizona v. David James Yonkman, 297 P.3d 902

Yonkman’s wife reported March 27, 2010 that he sexually molested her daughter; Yonkman invoked counsel after Miranda warnings at the residence interrogation.
A few days later, the wife recanted; Detective Rivera told Yonkman he could come in for a polygraph to close the case; Yonkman scheduled an interview for April 1.
At the station, Yonkman was told he was not in custody and could leave; Miranda warnings were read again when he consented to questioning.
Yonkman confessed after about 30 minutes; police arrest followed; defense moved to suppress the confession as Edwards-related and involuntary.
Arizona Court of Appeals reversed, suppressing based on Edwards reinitiation; the Arizona Supreme Court granted review to resolve whether third-party contact can reinitiate Edwards interrogation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did police reinitiate interrogation after the invocation of counsel?	Yonkman argues Edwards prohibits reinitiation by police, making his April 1 interview involuntary.	State contends no Edwards violation because third-party contact did not constitute police reinitiation and Yonkman himself resumed contact.	No reinitiation by police; interrogation not Edwards-initiated.
Did Yonkman’s own act of contacting police to arrange the interview constitute a valid reinitiation?	Yonkman initiated contact by calling Rivera to set up the interview.	Rivera’s prior contact with Kelly was not coercive; the initiation by Yonkman reinitiated dialogue.	Yonkman’s reinitiation occurred through his own contact, supporting admissibility.

Edwards v. Arizona, 451 U.S. 477 (1981) (reinitiation limits after invoking counsel; safeguards against coerced waivers)
Maryland v. Shatzer, 130 S. Ct. 1213 (2010) (custody-break rule; fourteen-day window after release for counsel invocation)
Michigan v. Harvey, 494 U.S. 344 (1990) (Edwards’ protections and timing considerations)
Montejo v. Louisiana, 556 U.S. 778 (2009) (noncustodial interactions and police pressures)
Rhode Island v. Innis, 446 U.S. 291 (1980) (definition of interrogation and functional equivalence)
Fox v. Ward, 200 F.3d 1286 (10th Cir. 2000) (police-contact initiation standards post-counsel)
Oregon v. Bradshaw, 462 U.S. 1039 (1983) (routine custodial inquiries do not generally reinitiate Edwards concerns)
Colorado v. Connelly, 479 U.S. 157 (1986) (fifth-amendment coercion considerations in police conduct)
Van Hook v. Anderson, 488 F.3d 411 (6th Cir. 2007) (third-party initiation not barred when suspect initiates discussion)