New York v. Quarles Case Brief
United States Supreme Court
467 U.S. 649 (1984)
ISSUE: Was an officer justified in questioning a D immediately upon detention about the whereabouts of a gun that the officer believed was missing without advising D of hisMiranda rights in the name of public safety?
HOLDING: Yes, the needs for answers in a situation posing a threat to the public safety outweighs the need for the prophylactic rule protecting the 5th Amdt.'s privilege against self-incrimination.
- Officers on patrol were approached by a woman who claimed she had just been raped by a man who had just entered a supermarket
- Officer Kraft entered the store, saw D, and ordered him to stop and put his hands up
- Kraft then frisked D and found that a gun was missing from the holster D was wearing, so he asked D where the gun was
- D said "the gun is over there," and then Kraft formally arrested D and read him is Miranda rights; D waived his rights and answered further questions
- Trial judge excluded all statements including "the gun is over there" and the evidence of the gun as being tainted by a Miranda violation
- Ct. App. and Sup. Ct. affirmed
- No coercion: No claim here that D's statements were actually compelled by police conduct
- "Public safety" exception: On these facts there is a public safety exception to the requirement thatMiranda warnings be given before questioning, and the availability of the exception does not depend on the subjective motivation of the individual officers involved
- Officers may be motivated by many different concerns in such a position
- So long as the gun was concealed somewhere in the supermarket, it posed a threat to public safety or to the officers
- Officer Kraft's questions were necessary, not for incriminating D, but for ensuring no further danger to the public was posed by the gun
- Miranda is the law, and the majority has not provided sufficient justification for departing from it for blurring its lines
- When police ask custodial questions without administering the required warnings, Miranda quite clearly requires that the answers received be presumed compelled and be excluded at trial
- No legitimate reason to interrogate D without first advising him of his Miranda rights
- Miranda Court clearly stated that the right against self-incrimination cannot be abridged
- Without establishing that interrogations concerning the public's safety are less likely to be coercive than other interrogations, the majority cannot endorse the public-safety exception and still remain faithful to Miranda
- Officer Kraft's questioning was coercive given the circumstances
- Officers can always question suspects without advising them of their rights, but the answers cannot be used at trial
- So remember when I said in my comments after Miranda v. Arizona that Miranda warnings must always be given? Well, nothing is ever that cut and dry, at least not in criminal procedure. Quarles carves out a small but important exception to the requirement that Miranda warnings be given. Remember exigent circumstances in Fourth Amendment jurisprudence? Well Quarles is like exigent circumstances in the Fifth Amendment/Miranda context. When the police are presented with a public safety emergency, such emergency obviates the need to give Miranda warnings.
- So what does Quarles mean to you and to law enforcement personnel? Well, when the police are presented with a public safety emergency (e.g., a missing gun in a supermarket), they may perform custodial interrogation without giving Miranda warnings. If the police capture a kidnapper and the victim is in imminent danger of dying and they ask, "Where is the victim?" without giving Miranda warnings, the answer to that question will fall under the Quarles exception to Miranda.
- The "public safety exception" doesn't only apply to public emergencies. If the police are presented with a situation posing an imminent danger to themselves or to the suspect, that qualifies as well. For example, there was one case where the police arrested a suspect suspected of dealing drugs. The suspect apparently swallowed his whole stash when pursued by the police and started convulsing. The police asked him what he had swallowed without Mirandizing him, and so the suspect told them. His answer fell within the Quarles exception to Miranda.
- So how far can law enforcement push Quarles? What about not Mirandizing terrorism suspects? This is currently a hot-button issue in our post-9/11 nation.