New York v. Quarles
Citation: 467 U.S. 649 (1984)
Facts
Officer Frank Kraft pursued a rape suspect, Benjamin Quarles, into a grocery store. After handcuffing Quarles, Kraft noticed an empty holster and asked, “Where’s the gun?” before administering Miranda warnings. Quarles nodded toward some boxes and said “The gun is over there.” A loaded revolver was found. The New York Court of Appeals suppressed the statement and the gun.
Issue
Whether there is a “public safety” exception to the Miranda requirement that permits police to ask questions before administering warnings when doing so is reasonably necessary to secure an immediate danger to the public.
Holding
The Supreme Court held that there is a public safety exception to Miranda. When police ask questions reasonably prompted by a concern for public safety — such as the location of a discarded weapon — the answers are admissible even if Miranda warnings have not been given.
Rule
Miranda warnings need not precede questioning when the officers’ questions are reasonably prompted by a concern for public safety. Statements made and evidence found in response to such questions are admissible.
Significance
Quarles established the most significant exception to Miranda and illustrates how the Court balances Fifth Amendment protections against other urgent public interests. It is studied alongside Miranda and subsequent cases limiting and preserving the warnings requirement, including Berkemer v. McCarty and Berghuis v. Thompkins.