New York v. Quarles
Following is the case brief for New York v. Quarles, 467 U.S. 649 (1984)
Case Summary of New York v. Quarles:
- After officers received a description of an assailant, one officer followed the suspect into a supermarket.
- Spotting respondent Quarles (the suspect), the officer ordered him to stop. The officer frisked Quarles and discovered that he was wearing an empty shoulder holster.
- The officer then asked Quarles where the gun was. Quarles responded, and the officer located the gun.
- The officer placed Quarles under arrest and read him his Miranda rights. Quarles made additional statements about where he purchased the gun after being read his rights.
- The trial court suppressed all of Quarles’ statements, as a violation of the Miranda rule. The New York appellate courts affirmed that decision.
- The U.S. Supreme Court reversed. It found a “public safety” exception to the Miranda rule, such that an officer may ask questions without reading the Miranda rights if there is an immediate need for information to protect public safety.
New York v. Quarles Case Brief
Statement of the Facts:
A woman approached two police officers on road patrol. The woman told the officers that she had been raped, she described her assailant, and she told them that the man had just entered a nearby grocery store with a gun. One of the officers went into the grocery store and ordered respondent Quarles to stop and put his hands over his head.
The officer frisked Quarles, discovering that Quarles was wearing an empty shoulder holster. The officer handcuffed Quarles and then asked him the location of the gun. Quarles indicated that it was in an empty carton in the store. The officer retrieved the gun, arrested Quarles, and read him his Miranda rights. Quarles then made statements about where he had purchased the gun.
- Before trial, Quarles moved to suppress his statements to the officer.
- The trial court excluded all of his statements. The court found that his statement about the location of the gun was made before he was read his Miranda rights, and the subsequent statements were tainted by the initial Miranda violation.
- Both the Appellate Division and the New York Court of Appeals affirmed the trial court’s decision.
- The U.S. Supreme Court granted certiorari.
Issue and Holding:
Should a statement about the location of a gun that may injure an innocent bystander, made before a suspect was read his Miranda rights, be suppressed? No.
The decision of the New York Court of Appeals is reversed and remanded.
Rule of Law or Legal Principle Applied:
There is a “public safety” exception to the Miranda rule, whereby Miranda rights do not need to be read before an officer can inquire about something that may pose a danger to public safety.
There is a “public safety” exception to the Miranda requirement. In this case, the officer asked about the location of the gun with an immediate interest in ensuring that it did not pose a danger to an innocent bystander, or fall into the hands of an accomplice. Therefore, the officer’s failure to read the Miranda warnings did not violate the Constitution. The majority is aware that the “public safety” exception will lessen the “desirable clarity” of the Miranda rule.
Concurring and Dissenting Opinions:
Concurring in Part, Dissenting in Part (O’Connor):
There is not sufficient justification to depart from the Miranda rule here, but the subsequent statements made after the warnings were given should be admitted.
Dissenting Opinion (Marshall):
The clear guidelines of the Miranda rule should not be abandoned in this case. This decision will lead to a new era of confusion on whether a custodial interrogation was conducted properly.
New York v. Quarles is a major Miranda decision because it created the “public safety” exception to the Miranda rule.