US Supreme Court New York v. Quarles 82-1213

Decided June 12, 1984

   This decision created the well-known public safety exception to Miranda.

   A couple of cops were approached by a woman who claimed that she had just been raped by a man with a gun.  She described the suspect, and said that he had gone to a particular supermarket.  The cops went to that store, where the found Quarles (who matched the suspect description).

   As soon as he saw the cops, Quarles took off running.  They chased, lost sight of him briefly, but caught him a moment later.  He was held at gunpoint, handcuffed, and searched, and there were at least four cops present.  He was in possession of an empty shoulder holster.

   One of the cops asked Quarles "Where's the gun?"  Quarles nodded to some boxes and told him the gun was over there.  After recovering the gun, the officer read Quarles the Miranda warnings.  Quarles waived his rights, and made some additional incriminating statements.

   The trial court suppressed the gun and Quarles' statements, reasoning that all of that evidence was tainted by the officer's failure to read Miranda before asking Quarles where the gun was.  The prosecution appealed all the way to the US Supreme Court.

   The Court explained that the Miranda warnings aren't actually constitutional rights themselves, but court-created procedural safeguards which protect the Fifth Amendment right against self incrimination.  At the time that the court had created this safeguard, it accepted that requiring officers to Mirandize suspects would result in fewer convictions.  But this situation is different: the gun which was discarded somewhere in the store posed a safety risk.  The court held that unlike the risk of a later acquittal, a present risk of physical harm is more important than the procedural safeguard of Miranda warnings.  The court also noted that Quarles' incriminating statements weren't obtained by the sort of coercion that Miranda was intented to prevent.  So the court created a narrow exception to Miranda, allowing unwarned statements in circumstances like these to be used as evidence by the prosecution (as long as those statements are the result of the sort of questioning which is necessary to address a safety risk).