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New York v. Quarles

Significance



The most important issue addressed by this case was whether an incriminating statement regarding information about where the respondent hid his gun, could be accepted as testimonial evidence at trial if a police officer failed to provide a Fifth Amendment Miranda rights warning before questioning his suspect. The U.S. Supreme Court reversed judgments of lower courts and explained that an exception to the Miranda rule was justified because the officer believed he needed to ensure public safety. In ruling as acceptable a departure from the required, very precise instructions of the Miranda rule, which ensured a suspect would not be subject to self-incrimination if Miranda warnings were not given, the U.S. Supreme Court gave guidance that in circumstances where public safety was at risk, it may be necessary and correct to forego Miranda warnings.



On 11 September 1980, shortly after midnight, two police officers, Frank Craft and Sal Scarring, were on patrol when a woman came to their car and told them she had been raped. She provided a description of an black male, six feet tall, armed, and wearing a black jacket. She also told officers he fled into a supermarket. Officer Craft rushed in to apprehend the suspect while his partner called for assistance. He recognized a man who matched the description and gave chase. Craft ordered his suspect to stop and put his hands over his head. Other officers convened and surrounded the suspect in back of the store, but Officer Kraft was the first to reach the man. Handcuffing the suspect, the officer noticed the man's empty shoulder holster and asked him where the gun was. The suspect nodded his head toward some empty boxes answering, "The gun is over there." Officer Craft secured the weapon then returned to inform the suspect, Benjamin Quarles, of his Miranda rights. Quarles decided to waive his Miranda rights and answer the officer's questions without an attorney's presence. He stated that he bought the revolver in Miami, Florida, and it was his.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1981 to 1988New York v. Quarles - Significance, Miranda Warnings Inadequate, A Compelling Exception, Impact, Self-incrimination Clause