Grizzell v. State

I agree with the conclusion in the main opinion that “[Joey A.] Grizzell’s statement on September 5, 2013, was taken in violation of Edwards[ v. Arizona, 451 U.S. 477 (1981), and that] the circuit court abused its discretion by denying Grizzell’s motion to suppress.” 186 So.3d at 483. I write separately, however, to express my reasons for concurring in the main opinion.

In Maryland v, Shatzer, 559 U.S. 98, 130 S.Ct. 1213, 175 L.Ed.2d 1045 (2010), the United States Supreme Court addressed the Edwards rule as follows:

“The Fifth Amendment, which applies to the States by virtue of the Fourteenth…