State v. Knowlton
2012 ME 3
| Me. | 2012Background
- MDEA agent Campbell investigated Knowlton's suspected drug trafficking involving Canada-based importation.
- Knowlton was approached at work on Jan 23, 2009, escorted to the Caribou Police Department, Mirandized, and promptly invoked the right to counsel.
- Knowlton remained in custody; family visits occurred and bail was set; he was moved to a holding cell and later transported to the county jail.
- During the drive to the jail, Knowlton discussed calling his mother; after the conversation, he indicated willingness to cooperate but feared speaking with police, and the officer warned him not to talk under advisement of counsel.
- Near the jail, Knowlton stated he wanted to talk; they proceeded to MDEA offices, where Knowlton signed a waiver falsely stating he had previously invoked but now would speak without an attorney; incriminating statements were made.
- Knowlton was indicted March 5, 2009; the trial court suppressed the statements, applying Maryland v. Shatzer's 14-day waiting period; the State appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Shatzer applies by custody-break requirement | State contends Shatzer controls; continuous custody negates lack of break. | Knowlton argues Edwards/Bradshaw framework governs initiation after invoke; no break in custody. | Shatzer does not control; Edwards/Bradshaw framework applies; remand. |
| Who initiated interrogation after invocation | Not explicitly stated; Campbell initiated further questioning after Knowlton’s invocation. | Knowlton’s statement that he wanted to cooperate constituted initiation of dialogue. | Remand to reassess initiation under Edwards/Bradshaw. |
| Whether Knowlton’s waiver was voluntary | Evidence could support voluntariness despite custodial pressures. | State failed to prove voluntariness beyond a reasonable doubt. | Remand; voluntariness not finally decided on this appeal. |
Key Cases Cited
- Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (post-invocation interrogation barred unless defendant initiates further communication)
- Oregon v. Bradshaw, 462 U.S. 1039 (U.S. 1983) (initiation by defendant distinguished from custodial inquiries; generalized discussion permitted if initiated by suspect)
- Maryland v. Shatzer, 559 U.S. _ (U.S. 2010) (fourteen-day break in custody governs reinitiation after release; not controlling here due to continuous custody)
- United States v. Fontana, 948 F.2d 796 (1st Cir. 1991) (initiation analysis after invocation may consider generalized discussion vs custodial incidents)