New York v. Quarles
467 U.S. 649 (1984)
Rule of Law:
There is a 'public safety' exception to the requirement that police officers must give Miranda warnings before conducting a custodial interrogation. Statements elicited from an unwarned suspect are admissible in court if the questioning was reasonably prompted by a concern for public safety.
Facts:
- A woman approached police officers, stating she had just been raped by a man who was carrying a gun and had entered a nearby A&P supermarket.
- She described the suspect, Benjamin Quarles, as a black male wearing a jacket with 'Big Ben' on the back.
- Officer Frank Kraft entered the supermarket, spotted Quarles, who matched the description, and pursued him toward the rear of the store.
- After a brief chase where he momentarily lost sight of Quarles, Officer Kraft cornered and ordered him to stop.
- Kraft frisked Quarles, who was now surrounded by several officers, and discovered he was wearing an empty shoulder holster.
- After handcuffing Quarles, but before reading him his Miranda rights, Officer Kraft asked him where the gun was.
- Quarles nodded toward some empty cartons and responded, 'the gun is over there.'
- Officer Kraft then retrieved a loaded .38-caliber revolver from one of the cartons.
Procedural Posture:
- Benjamin Quarles was charged with criminal possession of a weapon in a New York trial court.
- The trial court granted Quarles's motion to suppress his statement 'the gun is over there' and the gun itself as fruits of a Miranda violation.
- The State of New York appealed to the Appellate Division of the Supreme Court of New York, an intermediate appellate court, which affirmed the suppression order.
- The State then appealed to the New York Court of Appeals, the state's highest court, which also affirmed the suppression.
- The United States Supreme Court granted certiorari to review the decision of the New York Court of Appeals.
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Issue:
Does a police officer's failure to provide Miranda warnings before questioning a suspect in custody require suppression of the suspect's statement and its physical fruits when the questioning is reasonably prompted by a concern for public safety?
Opinions:
Majority - Justice Rehnquist
No. A public safety exception to the prophylactic Miranda rule is justified when police officers ask questions reasonably prompted by a concern for public safety. The need for answers in a situation posing a threat to public safety outweighs the need for the Miranda warnings, which are a procedural safeguard and not a constitutional right in themselves. The exception is based on an objective standard and does not depend on the officer's subjective motivation. Here, the presence of a discarded gun in a public supermarket created an immediate danger that justified Officer Kraft's question about its whereabouts before providing warnings.
Concurring-in-part-and-dissenting-in-part - Justice O'Connor
No, suppression of the gun is not required, but suppression of the statement is. A principled application of Miranda requires that respondent's statement, being the product of an unwarned custodial interrogation, must be suppressed. There is no justification for blurring Miranda's clear prophylactic lines with a new 'public safety' exception. However, the Fifth Amendment privilege protects against compelled testimonial evidence, not non-testimonial physical evidence. Therefore, while the statement itself is inadmissible, the gun—which is non-testimonial 'real or physical' evidence—should not be suppressed as a fruit of the Miranda violation.
Dissenting - Justice Marshall
Yes. Suppression of the statement is required because there is no 'public safety' exception to the clear constitutional rules established in Miranda, which presumes all unwarned custodial statements are coerced. The facts did not support a finding of exigent circumstances, as Quarles was handcuffed, surrounded by four officers, and the supermarket was nearly deserted. The majority's decision abandons Miranda's clarity, invites the introduction of coerced statements into criminal prosecutions, and will lead to endless post hoc litigation over what constitutes a public safety 'exigency'.
Analysis:
This decision established the significant 'public safety' exception, creating the first major judicially-created exception to the Miranda rule. It marks a shift from Miranda's rigid, prophylactic approach to a more flexible, context-dependent balancing test where immediate public safety concerns can outweigh the need to provide warnings. The ruling introduced an objective standard for police conduct in emergency situations but also blurred the previously bright-line rule, leading to future litigation over what circumstances constitute a sufficient threat to public safety to justify unwarned custodial interrogation.
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