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Law School Case Brief

New York v. Quarles - 467 U.S. 649, 104 S. Ct. 2626 (1984)

Rule:

There is a "public safety" exception to the requirement that Miranda warnings be given before a suspect's answers may be admitted into evidence, and the availability of that exception does not depend upon the motivation of the individual officers involved. In a kaleidoscopic situation where spontaneity rather than adherence to a police manual is necessarily the order of the day, the application of the public safety exception should not be made to depend on post hoc findings at a suppression hearing concerning the subjective motivation of the arresting officer.

Facts:

A police officer pursued respondent Benjamin Quarles in a supermarket after a woman identified him as the man who raped her. The officer frisked respondent and discovered that he was wearing an empty shoulder holster. After handcuffing respondent, the officer asked him where the gun was. Respondent said, "the gun is over there." After the officer retrieved the loaded gun, he placed respondent under arrest and read him his Miranda rights. In the subsequent prosecution of respondent for criminal possession of a weapon, the judge excluded the statement and the gun because the officer had not given respondent his Miranda warnings before asking him where the gun was located. The state appellate courts affirmed, rejecting petitioner State's argument that the exigencies of the situation justified the officer's failure to read respondent his Miranda rights until after he had located the gun.

Issue:

Did the exigencies of the situation justify the officer’s failure to read respondent his Miranda rights until after he had located the gun?

Answer:

Yes.

Conclusion:

The Court held that the case at bar presented a situation where concern for public safety must be paramount to adherence to the literal language of the prophylactic rules enunciated in Miranda. According to the Court, the doctrinal underpinnings of Miranda did not require that it be applied in all its rigor to a situation in which police officers ask questions reasonably prompted by a concern for the public safety. In the present case, the Court opined that so long as the gun was concealed somewhere in the supermarket, it posed more than one danger to the public safety: an accomplice might make use of it, or a customer or employee might later come upon it.

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