New York v. Quarles: Case Brief

Instructor: Brittany McKenna

Brittany is a licensed attorney who specializes in criminal law, legal writing, and appellate practice and procedure.

The Supreme Court's landmark New York v. Quarles decision introduced the public safety exception to the Miranda warning requirement related to police interrogations. This lesson discusses the facts of the case and the Supreme Court's decision.

Questions Presented to the Supreme Court

Have you ever watched a crime drama on television? If you have, you are probably familiar with the Miranda warnings, which usually start like this:

'You have the right to remain silent. Anything you use can be used against you in a court of law...'

These famous 'warnings' represent some very important constitutional rights, including the Fifth Amendment right against self-incrimination. Any statements made without the benefit of giving the Miranda warnings will be suppressed-- in other words, excluded from the suspect's subsequent prosecution.

Although a suspect's constitutional rights are extremely important, there are situations where the concern for public safety will take precedence. In the New York v. Quarles case, the Supreme Court considered a scenario like this and considered whether certain situations-- specifically, emergency situations-- would allow a police officer to question a suspect without giving the required Miranda warnings.

The Facts of New York v. Quarles

Police officers on patrol in New York were approached by a woman who reported that she had just been raped. The victim provided the officers with a description of the perpetrator and informed them that he had just entered a nearby grocery store. The victim warned the officers that the perpetrator was carrying a gun.

The officers located Benjamin Quarles in the grocery store. Quarles matched the description of the suspect. As the officers approached, Quarles fled. The officers gave chase, losing sight of Quarles in the store.

With weapons drawn, the officers caught up to Quarles and ordered him to place his hands on the head. They immediately frisked Quarles and found an empty gun-holster on his hip. The officer who searched Quarles asked, 'Where is the gun?' to which Quarles replied, 'The gun is over there.' The officer found the gun and arrested Quarles.

Quarles was charged with the illegal possession of a weapon. At his trial, the judge threw out all of the evidence relating to the gun-- including Quarles initial 'the gun is over there' statement -- on the grounds that the arresting officer failed to read Quarles his Miranda warnings before questioning him. The case was appealed to the Supreme Court.

The Holding and Analysis of the Supreme Court

In Quarles, the Supreme Court considered the important 'interests' at stake during police investigations and interrogations. The Supreme Court recognized that while the constitutional rights of a suspect are of great importance, there are instances where those rights must 'yield' to the interest of public safety.

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