This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
The trial court found that Blake was merely responding to Officer Reese’s statements, not initiating a new conversation, and that the interaction lasted 28 minutes.
Ms. Graeff argues that custody and voluntariness are mixed questions of fact and law; historical facts receive deference, but the ultimate question of custody and voluntariness is reviewed de novo.
Ms. Graeff contends that Detective Johns cured the impropriety by informing Blake that there would be no more questioning, leaving Blake free to choose whether to speak or remain silent.
According to Kenneth W. Ravenell, ravenell asserts that Edwards v. Arizona supports the view that a cure should not be applied unless the defendant himself initiates contact.
Ravenell argues that additional factors beyond the right to counsel should be considered, and that another fallback position is not needed.
Background and question before the Court
The trial court found that Blake was merely responding to Officer Reese’s statements, not initiating a new conversation, and that the interaction lasted 28 minutes.
What each side argues
Maryland (Petitioner)
Ms. Graeff argues that custody and voluntariness are mixed questions of fact and law; historical facts receive deference, but the ultimate question of custody and voluntariness is reviewed de novo.
Ms. Graeff contends that Detective Johns cured the impropriety by informing Blake that there would be no more questioning, leaving Blake free to choose whether to speak or remain silent.
According to Kenneth W. Ravenell, ravenell asserts that Edwards v. Arizona supports the view that a cure should not be applied unless the defendant himself initiates contact.
Ravenell argues that additional factors beyond the right to counsel should be considered, and that another fallback position is not needed.
Leeander Jerome Blake (Respondent)
Source-limited. The record does not yet support a complete account.
What happened at oral argument
What the Court decided
Why it matters
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- 913669b78bbde2bfac8d-r1-1648089627b37d6c.pdforal argument transcript
Guide generated September 21, 2026. Automated validation accepted this version.