New York v. Quarles

The U.S. Supreme Court reversed the decision of the lower courts. The Court found that the use of the Miranda warnings could be avoided when public safety was at issue. They explained the "immediate necessity of ascertaining the whereabouts of the gun" to ensure the safety of the public was important enough to justify an exception to Miranda v. Arizona (1966). Justices for the majority opinion reasoned that a suspect's associates "might make use" of the weapon or shoppers or employees might later find it. They pointed out that if officers were required to give Miranda warnings in such circumstances, it might deter the suspect from responding. Consequently, while the constitutional Miranda rights of a suspect would be secured, the risk of potential danger could be substantial. Justice Rehnquist wrote, "Officer Kraft 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."

The Court conceded that its decision would have the impact of reducing the "explicitness" of the Miranda rule. On the other hand, it believed that in order to ensure safety to life and limb, police officers had to retain the ability to instinctively judge the conditions in any given situation. The majority opinion went on to suggest that although Miranda safeguards against self-incrimination were abandoned, in certain situations when swift action is needed officers may have to decide whether it was appropriate to "ask necessary questions without the Miranda warnings." Such a decision could "render whatever probative evidence they uncover inadmissible." Or an officer may decide to "give the warnings in order to preserve admissibility of evidence they might uncover but possibly damage or destroy their ability to obtain that evidence and neutralize the volatile situation confronting them." Thus, in light of its findings, the Court reversed and remanded the case for readjudication by a lower court.

Justice O'Connor concurred in part and dissented in part. She opined that the Court's arguments did not justify making a departure from the clear prospect of the Miranda rule. The Self-Incrimination Clause should have been considered a safeguard against interrogations that could implicate involuntary confessions or disclose evidence connected with a crime. Justice O'Connor thus maintained that unequivocal application of Miranda warnings should be exercised. She reasoned that "society's need for interrogation" (e.g., Officer Craft's question about the gun) should not usurp the guards assumed in Miranda. Thus, to accurately enforce Miranda warnings, it is only necessarily to prevent an "admission of testimonial self-incriminations." However, Justice O'Connor agreed with the majority opinion that the lower courts incorrectly suppressed the gun as evidence. Incrimination with non-testimonial evidence could not be considered a violation of privilege against self-incrimination. Justice O'Connor regarded the gun as physical evidence, and finding that the gun could not be categorized as testimonial evidence, she held that suppression of the gun was unjustified.

The dissenting justices pointed out that the respondent, Quarles "had been reduced to a condition of physical powerlessness" when he was asked about the gun. Justices found it difficult, therefore, to believe Quarles, who did not have any accomplices, was a significant danger to anybody. The dissenting justices rejected the petitioner's assertion that interrogation without Miranda warnings was appropriate because of a risk to public safety. The supermarket was almost empty. Quarles was apprehended around midnight, and police could have easily conducted a search after arresting their suspect. The dissenting justices reasoned that because the weapon was out of sight it "did not pose a risk either to the arresting officers or to the public."

In writing the dissenting opinion, Justice Marshall voiced the minority view that majority justices made assumptions which seemed to represent an "abuse of the facts." They could not conceive any reason to justify any departure from Miranda. They did not agree that the police officers were faced with the dilemma of having to choose between "establishing the suspect's guilt and safeguarding the public from danger." Miranda v. Arizona (1966) was established to address procedural safeguards when suspects were taken into custody; its explicit purpose was to provide law enforcement with definitive protocol which would protect a suspect's rights during while he was being questioned. It was unacceptable to deviate from due process of law and to nullify the years of explicitness represented by Miranda. The minority justices thus felt their position voiced resolute support of the Fifth Amendment in finding fault with allowing an invalid concern for "public safety" to justify departure from the common explicitness of the Miranda rule.

The minority justices believed that under Miranda, "coerced confessions were simply inadmissible in criminal prosecutions." To do otherwise interfered with due process. Thus, it was especially disturbing to the justices that although Quarles was handcuffed and surrounded by officers in the back of the store, the majority did not find such circumstances to be coercive. (Justice Marshall's opinion apparently was referring to the manner in which the majority opinion characterized circumstances of Quarles' arrest as "instinctive.") The minority justices felt the arresting officer's conduct did not correctly adhere to Miranda "safeguards" which would have ensured an untainted gathering of criminal evidence. By not reading the suspect his rights prior to questioning, the officer's conduct had to be viewed as unacceptably coercive. Thus, the gun, obtained as a direct product of forcible, improper inquiry, represented inadmissible evidence because, in direct violation of the Miranda rule, it was "derived from an illegally obtained source."