State v. Jackson
1988 WL 84497, 756 S.W.2d 620, 1988 Mo. App. LEXIS 1167 (1988)
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Rule of Law:
The public safety exception to the Miranda rule allows police to question a suspect about the location of a weapon before providing Miranda warnings if the question is reasonably prompted by a concern for the officer's own safety or the safety of the public.
Facts:
- In the early morning of November 14, 1986, police were dispatched to a reported shooting.
- Officer Morton arrived to find a woman standing near a man's body; she indicated the shooter was inside the residence.
- Morton entered the residence and saw the defendant, who began a rambling discourse about shooting the victim.
- Seeing no weapon, Morton asked the defendant, "Where’s the gun?" to ensure his own safety.
- The defendant replied that the gun was in the bedroom.
- After the gun was secured, the defendant was read his Miranda rights and subsequently confessed multiple times.
Procedural Posture:
- The defendant filed pre-trial motions in the trial court to suppress his statements and the seized gun.
- The trial court denied the defendant's motions.
- After a jury trial, the defendant was convicted of voluntary manslaughter.
- The defendant appealed his conviction to the Missouri Court of Appeals, the intermediate appellate court.
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Issue:
Does the public safety exception to the Miranda rule permit the admission of a suspect's statement about the location of a weapon, made in response to a police officer's question asked inside the suspect's residence before Miranda warnings were given, when the officer's question was aimed at securing his own safety?
Opinions:
Majority - Pudlowski, Chief Judge
Yes. The public safety exception to the Miranda rule permits the admission of the statement. Citing New York v. Quarles, the court held that there is a public safety exception to the requirement that Miranda warnings be given before a suspect’s answers may be admitted into evidence. The court reasoned that this exception is not limited to situations in public spaces but extends to any situation where questions are necessary to secure an officer's own safety. Officer Morton's question was not designed to elicit testimonial evidence but to determine if the suspect was still armed, thus neutralizing a potential threat. Because the initial statement and the gun were lawfully obtained under this exception, the defendant's subsequent, post-Miranda confessions were not tainted.
Analysis:
This decision clarifies the scope of the public safety exception established in New York v. Quarles, confirming that it is not limited to incidents occurring in public places with bystanders. The ruling extends the exception's application to situations within a private residence where an officer's safety is the primary concern. By focusing on the objective need to secure a dangerous situation rather than the location, the case provides law enforcement with greater latitude to ask narrowly tailored questions to neutralize immediate threats before administering Miranda warnings.
