New York v. Quarles

New York v. Quarles, 467 U.S. 649 (1984), was a decision by the United States Supreme Court regarding the public safety exception to the normal Fifth Amendment requirements of the Miranda warning.
Background.
The Supreme Court considered the admissibility of a statement elicited by a police officer who apprehended a rape suspect who was thought to be carrying a firearm. The arrest took place in an open but empty grocery store. When the officer arrested the suspect, he found an empty shoulder holster, handcuffed the suspect, and asked him where the gun was. The suspect nodded in the direction of the gun (which was near some empty cartons) and said, "The gun is over there".
The suspect was not prosecuted for rape, but was charged with criminal possession of a weapon. However, he argued that his statement ("The gun is over there") was inadmissible in evidence because he had not first been given the Miranda warning. Since the gun was found as a direct result of the statement, he argued that the presence of the gun was also inadmissible, making it impossible to convict him.
Judgment.
In a 5-4 decision, the Supreme Court found that the jurisprudential rule of "Miranda" must yield in "a situation where concern for public safety must be paramount to adherence to the literal language of the prophylactic rules enunciated in Miranda". The rule of "Miranda" is not, therefore, absolute and can be a bit more elastic in cases of public safety. Under this exception, to be admissible in the government's direct case at a trial, the questioning must not be "actually compelled by police conduct which overcame his will to resist," and must be focused and limited, involving a situation "in which police officers ask questions reasonably prompted by a concern for the public safety."
The suspect's unadvised statement was therefore admissible in evidence because "[i]n 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 we recognize today should not be made to depend on "post hoc" findings at a suppression hearing concerning the subjective motivation of the police officer".
Dissent.
Justice Marshall, joined by Justices Brennan and Stevens, rejected the idea of a public safety exception:
Furthermore, even if a public safety exception was allowed, he believed it would have been inapplicable in this particular case:
Justice O'Connor filed a separate opinion, also rejecting the idea of a public safety exception, but arguing that the presence of the gun itself should still be admissible evidence.