Sunday, May 17, 2009

New York v. Quarles, 467 U.S. 649 (1984)

Facts

Officers were told by a woman that she had been raped and that her rapist had entered a supermarket.  Police entered and Quarles fled.  The officer followed Quarles and instructed him to get on the ground.  The officer noticed Quarles had an empty holster, asked where the gun was, and Quarles responded.

Procedural History

Quarles moved to suppress his statement because his Miranda warnings had not been given to him.  The trial court granted the suppression.  The Court of Appeals affirmed, declining to recognize an exigency exception for protection of safety.

Issue(s)

Did the Court of Appeals err in affirming the suppression and refusing to find that the officer was faced with an exigency of public safety and thus not required to give Miranda warnings prior to questioning the location of the gun?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that on these facts there is a public safety exception to the requirement that Miranda warnings be given.  We do not believe that the doctrinal underpinnings of Miranda require that it be applied in all its rigor to a situation in which police officers ask questions prompted by a concern for public safety.

Judgment/Outcome

The Court reversed and remanded the judgment of the Court of Appeals.

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