Shuler v. State

Summary

The Supreme Court of Maryland held that the voluntariness requirement and the associated pattern jury instruction apply to a defendant's custodial statement regardless of whether the State offers it for impeachment or the statement is facially exculpatory, rejecting two of the Appellate Court's rationales. Nevertheless, the court held that Shuler failed to produce “some evidence” that his Mirandized, roughly 15-minute custodial statement was involuntary, so the trial court did not err in refusing MPJI-Cr 3:18, and it further held in the alternative that any such error was harmless beyond a reasonable doubt given the statement's strictly impeachment use, the limiting instruction, and the ample other evidence of guilt. The judgment of the Appellate Court was accordingly affirmed. Watts, J., concurring in part and dissenting in part, joined on the evidentiary point by Biran, J., would have held that Shuler's cut-off question about counsel during the Miranda advisement generated “some evidence” requiring the instruction.