ABSTRACT
CAPSULE: Concern for public safety represents an exception to the Miranda rule. FACTS: Officers were approached by a woman claiming that she had just been raped by an armed man. She described him and said that he had entered a nearby supermarket. The officers drove the woman to the supermarket and one officer went in while the other radioed for assistance. The officer in the supermarket quickly spotted Quarles, who matched the description provided by the woman, and a chase ensued. The officer ordered Quarles to stop and place his hands over his head. The officer frisked Quarles and discovered an empty shoulder holster. After handcuffing Quarles, the officer asked him where the gun was. Quarles nodded in the direction of some empty cartons and responded, “the gun is over there.” The gun was retrieved from the cartons and Quarles was placed under arrest and read his Miranda warnings. Quarles indicated that he would answer questions without an attorney present and admitted that he owned the gun. ISSUE: Were the suspect’s initial statements and the gun admissible in evidence despite the failure of the officer to give him the Miranda warnings prior to asking questions that led to the discovery of the gun? YES. SUPREME COURT DECISION: Responses to questions asked by a police officer that are reasonably prompted by concern for public safety are admissible in court even though the suspect was in police custody and was not given the Miranda warnings. REASON: “We hold that on these facts there is a ‘public safety’ exception to the requirement that Miranda warnings be given before a suspect’s answers may be admitted into evidence, and that the availability of that exception does not depend upon the motivation of the individual officers involved. In a kaleidoscopic situation such as the one confronting these officers, where spontaneity rather than adherence to a police manual is necessarily the order of the day, the application of the exception which we recognize today should not be made to depend on post hoc findings at a suppression hearing concerning the subjective motivation of the arresting officer. Undoubtedly most police officers, if placed in Officer Kraft’s position, would act out of a host of different, instinctive, and largely unverifiable motives-their own safety, the safety of others, and perhaps as well the desire to obtain incriminating evidence from the suspect.” CASE SIGNIFICANCE: New York v. Quarles carves out a “public safety” exception to the Miranda rule. The Supreme Court argued that the case presents
a situation in which concern for public safety must be paramount to adherence to the literal language of the rules enunciated in Miranda. Here, although Quarles was in police custody and therefore should have been given the Miranda warnings, concern for public safety prevailed. In this case, reasoned the Court, the gun was concealed somewhere in the supermarket and therefore posed more than one danger to the public. The Court hinted, however, that the “public safety” exception needs to be interpreted narrowly, and added that 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 testimony evidence from a suspect.
