Maryland v. Shatzer

In 2003, police interviewed imprisoned Michael Shatzer (defendant) about allegations he abused his young son; Shatzer invoked his right to counsel and the interview ended, and the investigation was closed. Two and a half years later, after new details of the allegation surfaced, a different detective went to interview Shatzer — again in prison, but following a lengthy gap — obtained a Miranda waiver, and eventually secured a confession after a failed polygraph, at which point Shatzer requested counsel and questioning stopped.