New York v. Quarles: Supreme Court Case, Arguments, Impact

The Public Safety Exception

An officer places handcuffs on a suspect

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In New York v. Quarles (1984), the Supreme Court created the "public safety" exception to the Miranda rule. Under Miranda v. Arizona, if an officer interrogates a suspect without notifying him of his Fifth Amendment rights, evidence gathered from that interrogation cannot be used in court. Under New York v. Quarles, however, an attorney may argue that evidence should be admissible because the officer acted in the interest of public safety when securing certain information from a suspect without issuing Miranda warnings.

Fast Facts: New York v. Quarles

  • Case Argued: January 18,1984
  • Decision Issued: June 12, 1984
  • Petitioner: The People of New York
  • Respondent: Benjamin Quarles
  • Key Questions: Can evidence offered by a defendant prior to receiving his Miranda warnings be used in court if there is a public safety concern?
  • Majority Decision: Justices Burger, White, Blackmun, Powell, and Rehnquist
  • Dissenting: Justices O'Connor, Marshall, Brennan, and Stevens
  • Ruling: The Supreme Court ruled that, due to a public safety concern, Quarles' statement regarding the location of his gun could be used against him in court even though he had not been read his Miranda rights at the time.

Facts of the Case

On September 11, 1980 officer Frank Kraft entered an A&P supermarket while on patrol in Queens, New York. He identified a man, Benjamin Quarles, who matched the description of an assailant armed with a gun. Officer Kraft moved to detain Quarles, pursuing him through the aisles. During the chase, three officers arrived on the scene. Officer Kraft caught up to Quarles and handcuffed him. The officer noticed that Quarles had an empty gun holster on him. Officer Kraft asked where the gun was and Quarles directed the officer to a revolver stashed inside a carton. After securing the gun, Officer Kraft read Quarles his Miranda rights, formally placing him under arrest.

Constitutional Issues

Was Quarles’ statement about the location of the gun subject to the exclusionary rule under the Fifth Amendment? Can evidence offered by a defendant prior to receiving his Miranda warnings be used in court if there is a public safety concern?

Arguments

The petitioner argued that it was the officer’s obligation to find and secure the gun in the interest of public safety. The gun could have been within reach of Quarles, placing everyone in the supermarket at risk, the attorney argued. The "exigent circumstances" of a gun hidden in the supermarket overrode the immediate need for Miranda warnings, the attorney told the court.

An attorney on behalf of Quarles argued that the officer should have notified Quarles of his Fifth Amendment rights as soon as he apprehended him. The attorney noted that the act of restraining Quarles and handcuffing him should have prompted the officer to read the Miranda warnings. Questions about the gun should have been asked after administering Miranda when Quarles was aware of his right to remain silent. The attorney called it a "classic coercive situation."

Majority Opinion

Justice Rehnquist delivered the 5-4 opinion. The court found that Quarles' statement, directing the officer to the gun, could be used as evidence. The decision in Miranda v. Arizona, according to the court, aimed to reduce police coercion of suspects in custody by advising them of their constitutional rights. When Officer Kraft apprehended Quarles, he reasonably believed that Quarles' gun was loose in the supermarket. His question was prompted by a concern for public safety. The immediate need to find a potentially dangerous weapon outweighed the need to administer Miranda in that instant.

Justice Rehnquist wrote:

"We think police officers can and will distinguish almost instinctively between questions necessary to secure their own safety or the safety of the public and questions designed solely to elicit testimonial evidence from a suspect."

Dissenting Opinion

Justice Thurgood Marshall was joined by Justice William J. Brennan and Justice John Paul Stevens. Justice Marshall argued that Quarles was surrounded by four officers, weapons drawn, when he was handcuffed. There was no "immediate concern" for public safety that overpowered the need to provide Miranda warnings. Justice Marshall argued that the Court would create "chaos" by allowing public safety to create an exception to the practices outlined in Miranda v. Arizona. According to the dissent, officers would use the exception to coerce defendants into making incriminating statements that would be admissible in court.

Justice Marshall wrote:

"By finding on these facts justification for unconsented interrogation, the majority abandons the clear guidelines enunciated in Miranda v. Arizona, 384 U. S. 436 (1966), and condemns the American judiciary to a new era of post hoc inquiry into the propriety of custodial interrogations."

Impact

The Supreme Court affirmed the presence of a "public safety" exception to Miranda warnings established under the Fifth Amendment of the U.S. Constitution. The exception is still used in court to allow evidence that would otherwise be inadmissible under Miranda v. Arizona. However, courts do not agree on what constitutes a threat to public safety and whether that threat needs to be immediate or not. The exception has been used in situations where officers need to locate a deadly weapon or injured victim.

Sources

  • New York v. Quarles, 467 U.S. 649 (1984).
  • Rydholm, Jane. The Public Safety Exception to Miranda. Nolo, 1 Aug. 2014, www.nolo.com/legal-encyclopedia/the-public-safety-exception-miranda.html.