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New York v. Quarles

Miranda Warnings Inadequate



Benjamin Quarles was charged with criminal possession of a gun. (Under New York Penal Law, "any person who possesses a loaded firearm outside of his home or place of business is guilty of criminal possession of a weapon in the third degree.") The trial court elected to exclude the respondent's evidential testimony, "The gun is over there," and the physical evidence, a .38 caliber revolver, because Miranda warnings were not given to Quarles before the officer asked him the location of the gun. The New York Appellate Division of the New York Supreme Court and the New York Court of Appeals affirmed the lower court's decision to suppress Quarles's statements. Because Officer Kraft failed to advise Quarles of his rights before asking any questions, the court believed the Miranda warning was inappropriately omitted. The court of appeals did not accept the state of New York's contention that the police officer was in a situation where the safety of himself, fellow officers, and the public had to be protected. The appellate court held that any interrogation before giving Miranda warnings, such as questioning about the location of the gun, was in violation of Fifth Amendment rights, which states that "No person shall be compelled in any criminal case to be a witness against himself." Consequently, because due process was violated, lower court rulings were affirmed.



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