New York v. Quarles, 467 U.S. 649 (1984)
After a woman told officers that she had been raped and that the perpetrator had run into a store carrying a gun, a police officer chased and caught Quarles, the defendant. When he frisked him, the officer noticed that Quarles was wearing an empty gun holster, so after handcuffing him, he asked where the gun was. Quarles responded, ‘‘The gun is over there.’’ The gun was recovered and Quarles was read his Miranda rights. The statement and the gun were excluded from evidence by the trial court as illegal fruits of that statement, which was affirmed by the appellate division of the New York Supreme Court and the New York Court of Appeals.
The lower courts based their decisions on the SupremeCourt determination that in the course ofmaking an arrest, the Fifth Amendment of the U.S. Constitution requires certain protections against compulsory self-incrimination to individuals who are interrogated by police. Because the nature of custodial interrogation is inherently coercive, the court in Miranda v. Arizona (1966) determined that prior to such interrogation a suspect must be warned of his rights. In the case of New York v. Quarles, the Supreme Court reversed the lower courts’ decisions, finding a ‘‘public safety’’ exception to the Miranda requirement that warnings be read to a suspect before custodial interrogation. This exception allows police officers to act in exigent circumstances where there is a threat to the safety of the public while permitting admission of evidence gathered.
References and Further Reading
- Weisselberg, Charles, Saving Miranda, Cornell Law Review 84 (1998): 109.
Cases and Statutes Cited
- Miranda v. Arizona, 384 U.S. 436 (1966)