New York v. Quarles
467 U.S. 649, 104 S.Ct. 2626, 81 L.Ed.2d 550 (1984)

  • The police were in hot pursuit of a rapist matching Quarles’ description. They found him in a grocery store. Quarles saw the police and ran. They caught him.
  • The policeman noticed that Quarles had an empty holster. While handcuffing him, and before reading Quarles his Miranda Warning, the policeman asked, “where’s the gun?” Quarles told the policeman he’d stashed the gun behind some cartons.
    • After retrieving the gun, the police read Quarles a Miranda Warning and formally arrested him. Miranda waived his right to remain silent and told the police that it was his gun.
  • At trial for the gun possession charge, the Trial Judge suppressed Quarles’ statement about the location of the gun, as well as the gun itself. The prosecutor appealed.
    • The Trial Court found that since Quarles has not been read his rights, as required by Miranda v. Arizona (384 U.S. 486 (1966)), his statement was inadmissible as a violation of the 5th Amendment right against self-incrimination.
  • The New York Supreme Court affirmed. The prosecutor appealed.
    • The New York Supreme Court found that there might be an exception to the Miranda Warning when the police are concerned with their own safety, but in this case, Quarles was clearly not in possession of the gun, so there was no risk to the police.
  • The US Supreme Court reversed and found the evidence admissible.
    • The US Supreme Court found that the overriding considerations of public safety justify the police officer’s failure to provide a Miranda warning before he asked questions devoted to locating the abandoned weapon.
    • The US Supreme Court found that there is a public safety exception to the requirement for a Miranda warning.
      • Basically, if the purpose of the questioning is not to elicit a confession, but for some other good (like finding a missing weapon before someone accidentally gets hurt), then the Miranda warning is not an absolute requirement.
        • The point of the Miranda warning is to deter the police from excessively coercing a suspect into making a false confession. But we don’t want the police to be deterred from finding dangerous weapons hidden in grocery stores.
          • Compare to the exceptions to the requirement for a warrant in search and seizure cases.
        • “The officer needed an answer to his question not simply to make his case against Quarles, but to insure that further danger to the public did not result from the concealment of the gun in a public area.”
  • In a dissent it was argued that there is nothing stopping the police from asking questions of suspects before reading them their rights, it just makes the statements inadmissible. If the police were really concerned with public safety, they could ask a question knowing that it might hurt later prosecution, it’s their choice.
    • The dissent suggested that the real question was who should bear the cost of securing public safety when such questions are asked, the defendant or the State?
  • This case illustrates the difference between actual coercion and presumptive coercion:
    • If the police had threatened to punch Quarles in the face, that would be actual coercion and would never be admissible under any circumstances.
      • In this case, there was no evidence that Quarles’ statement was compelled (which would be an absolute violation of the 5th Amendment).
    • Presumptive coercion is just a prophylactic concept to deter the police from stepping over the line. But it isn’t an absolute 5th Amendment requirement.
      • Miranda warning is designed to deter presumptive coercion, but since it isn’t a Constitutional requirement, the courts are free to balance the rights of suspects with other factors (like public safety).